Title
People vs. Magtibay y Bachoco
Case
G.R. No. 142985
Decision Date
Aug 6, 2002
A 1997 rape case where the accused, despite claiming illness as an alibi, was convicted based on the victim’s credible testimony, medical evidence, and ordered to pay damages and child support.
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Case Summary (G.R. No. 142985)

Overview of the Case

  • The case involves the appeal of Raymundo Magtibay y Bachoco against a decision by the Regional Trial Court of Pinamalayan, Oriental Mindoro, which found him guilty of rape and sentenced him to reclusion perpetua.
  • The Information charged Magtibay with having carnal knowledge of Rachelle Recto y Rafal through force and threats on September 15, 1997.
  • The trial court's decision was based on the testimonies of the victim and supporting witnesses, as well as medical evidence confirming the victim's pregnancy.

Prosecution's Version of Events

  • Rachelle Recto testified that on the evening of September 15, 1997, she went to a nearby store and encountered Magtibay, who was staring at her.
  • On her way home, Magtibay approached her, threatened her life, and forced her to lie down in a grassy area where he raped her.
  • Rachelle did not report the incident immediately due to fear of retaliation but eventually disclosed it to her mother after becoming pregnant.

Testimonies of Supporting Witnesses

  • Rachelle's mother, Gaudiosa Recto, learned of the rape when Rachelle was required to undergo an x-ray examination, which revealed her pregnancy.
  • Dr. Ronaldo Fetalberto, the Municipal Health Officer, confirmed Rachelle's pregnancy and noted physical signs of sexual assault during his examination.

Defense of the Accused

  • Magtibay claimed he was bedridden with influenza at the time of the alleged rape, supported by his wife and a neighbor who testified to his illness.
  • The defense argued that his alibi was credible and that he could not have committed the crime due to his condition.

Trial Court's Judgment

  • The trial court found Magtibay guilty and sentenced him to reclusion perpetua, ordering him to pay civil indemnity to Rachelle Recto.
  • The court emphasized the credibility of Rachelle's testimony and the lack of evidence supporting the defense's claims.

Appeal and Arguments

  • Magtibay appealed, arguing that the trial court erred in believing Rachelle's testimony, which he claimed was rehearsed and implausible.
  • He contended that the prosecution failed to prove his guilt beyond a reasonable doubt.

Credibility of the Victim's Testimony

  • The court reiterated that the credibility of the victim is crucial in rape cases, and it generally defers to the trial court's assessment of witness credibility.
  • Rachelle's testimony was found to be consistent and credible, despite the defense's attempts to discredit her.

Legal Standards for Rape

  • The court clarified that the absence of physical resistance does not negate the occurrence of rape, as the law does not require a victim to prove resistance.
  • The intimidation and fear experienced by the victim were sufficient to establish the crime.

Addressing the Defense's Claims

  • The court dismissed the defense's argument that Rachelle's testimony was rehearsed, noting that minor inconsistencies do not undermine the core of her account.
  • The identification of Magtibay as the perpetrator was deemed reliable, g...continue reading

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