Title
People vs. Rejano
Case
G.R. No. 105669-70
Decision Date
Oct 18, 1994
Jerry Rejano convicted of raping a 12-year-old twice; alibi rejected, victim’s testimony upheld despite delayed reporting. Supreme Court affirmed reclusion perpetua.
A

Case Summary (G.R. No. 105669-70)

Applicable Law

The prosecution of the case is grounded in the provisions under the Revised Penal Code regarding the crime of rape. Article 335 delineates the circumstances under which carnal knowledge of a woman is considered rape, particularly emphasizing instances of force and intimidation, and it is pertinent to note that the complainant was under twelve years of age.

Proceedings and Evidence

On June 19, 1991, the complaints were filed with the Regional Trial Court (RTC) of Malolos, Bulacan, and the cases were consolidated and heard under Branch 11. Rejano was arraigned on August 16, 1991, entering a plea of not guilty. The trial involved five witnesses for the prosecution and four for the defense. The complainant, born on January 26, 1978, detailed her harrowing experiences which substantiated her claims through consistent and vivid testimony of both rapes, including the immediate aftermath and her subsequent fear of retaliation from Rejano.

Testimony of the Complainant

Maristela Santiago testified that during the first incident in August 1990, she was in an isolated field gathering crabs when Rejano accosted her, forcibly removed her clothing, and raped her despite her desperate pleas for help. She described her pain and the traumatic aftermath of the assault, which included concealing the incident from her mother due to fear.

In December 1990, she similarly faced assault when she went to Rejano’s house to borrow a bicycle. He brandished a knife during the second incident, further instilling fear and compliance in her. Even amidst discomfort and intimidation, she managed to return home and participated in family activities, suppressing the trauma she faced.

Medical Examination and Findings

A medical examination conducted on February 4, 1991, by Dr. Ronaldo M. Mendez, revealed an old healed laceration which, while significant, did not negate the possibility of subsequent assaults as reiterated by expert testimonies. The findings indicated that the complainant's hymenal orifice was wide enough to permit penetration without necessarily causing a new injury, thus supporting the prosecution’s assertion of multiple incidents of rape.

Defense and Appellant's Claims

Rejano's defense hinged on denial and an alibi, claiming that he was in Mindoro during the time of the first rape. However, he failed to present credible evidence or witnesses to corroborate this claim, positioning an inherent weakness in his defense. His argument also focused on questioning the complainant's credibility based on her reaction and behavior during and after the assaults, including her delayed report of the events.

Court's Rationale and Decision

The court affirmed the trial court's decision, underscoring the credibility of the complainant’s testimony, which was deemed direct and str

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