Case Summary (G.R. No. 128889)
Applicable Law
The case is governed by the 1987 Philippine Constitution, relevant provisions of the Revised Penal Code, particularly Article 335 modified by R.A. No. 7659, which pertains to the imposition of death penalty in cases of rape of minors below twelve years old.
Case Background and Prosecution’s Evidence
The prosecution presented credible evidence, including testimonies from several witnesses. These included Helen Sudaria, KRISTINE's mother, who, after noticing abnormal discharge from her daughter's underwear, took her to the hospital where doctors confirmed the presence of gonorrhea. Helen's urgent response led to the filing of a complaint with law enforcement, and KRISTINE identified DIZON as her assailant during a police line-up. Medical examinations corroborated the claim of rape, revealing lacerations in KRISTINE’s hymen and the detection of gonorrhea.
Defense and Accusation Denial
DIZON, who had a close and long-standing relationship with the victim's family as an employee, testified in his defense, asserting his innocence and denying any misconduct. He disputed the circumstances under which he was investigated and claimed he did not have the opportunity to commit the alleged crime, pointing to KRISTINE’s lack of immediate disclosure about the incident and some inconsistencies in her testimony.
Trial Court's Findings
The trial court found the prosecution's witnesses credible and the testimonies sufficient to support a conviction beyond reasonable doubt. The court underscored that the victim's testimony alone could suffice for a rape conviction, given the presumption that a declaration by a victim of sexual assault is inherently reliable, especially when corroborated by medical evidence.
Appellate Review and Issues Raised
In his appeal, DIZON contended that the trial court erred in its findings, particularly regarding the weight and credibility of the evidence against him. He also emphasized the constitutional presumption of innocence and argued that the prosecution's evidence was insufficient to overcome reasonable doubt regarding his guilt. The Office of the Solicitor General maintained that the trial court's assessment of witness credibility should not be disturbed because the trial court had the advantage of observing the witnesses firsthand.
Court of Appeals Evaluation on Credibility
The appellate court emphasized that an inability to recall the specific date of an incident does not invalidate the testimony given by a victim, affirming that factual inconsistencies may arise but do not inherently compromise the credibility of the victim's account. The court recognized that the victim's emotional and psychological responses to trauma may delay or inhibit immediate reporting.
Imposition of Penalty and Damages
The court upheld the conviction and the imposition of the death penalty, reasoning that the legal framework at the time classified t
...continue readingCase Syllabus (G.R. No. 128889)
Background of the Case
- The case involves Avelino Reyes Dizon alias Lino (hereafter referred to as DIZON), who was convicted of rape against six-year-old Kristine Sudaria (hereafter referred to as KRISTINE).
- The conviction took place in the Regional Trial Court of Iba, Zambales, Branch 70, which found DIZON guilty beyond reasonable doubt and sentenced him to death, as well as requiring him to pay moral damages to the victim.
- The case is subject to automatic review under Article 47 of the Revised Penal Code, following amendments from R.A. No. 7659.
Accusatory Details
- DIZON was charged with committing rape on or about May 1994 in Brgy. Carael, Botolan, Zambales.
- The information specified that he used force and intimidation to have carnal knowledge of KRISTINE, a minor, against her will.
Prosecution's Case
- Various witnesses were presented by the prosecution, including:
- Helen Sudaria (mother of KRISTINE)
- Medical professionals: Dr. Fe Evangeline E. Lim and Dr. Felipe L. Arriola
- Members of law enforcement: SPO3 Moises J. de la Cruz, SPO1 Eduardo Santos
- The victim herself, KRISTINE
- Helen Sudaria testified about her daughter's stomach ache and subsequent medical findings of gonorrhea, leading to filing a complaint of rape.
- Medical examinations revealed lacerations and infections consistent with sexual assault.
Testimonies and Evidence
Helen Sudaria:
- Noticed unusual vaginal discharge in her daughter on July 20, 1994.
- Took KRISTINE to the hospital and later filed a complaint with the police.
Dr. Felipe Arriola:
- Conducted a medical examination of KRISTINE and noted healed lacerations on her hymen.
Dr. Fe Evangelista Ela-Lim:
- Confirmed the findings of gonorrhea and lacerations during her examination o