Case Summary (G.R. No. 172607)
Appellant’s Denial and Alibi
Umanito denied leaving his home on the date and claimed he spent the evening completing family work on picture frames. He admitted a prior courtship of AAA, which she allegedly rejected, but asserted that she frequently visited him and had a relationship with another man.
RTC Findings and Conviction
The RTC found AAA credible despite minor inconsistencies, dismissed the alibi for lack of proof of physical impossibility, and held that force and intimidation were evident. Umanito was convicted of rape, sentenced to reclusion perpetua, and ordered to pay P50,000 indemnity.
CA Affirmation
The Court of Appeals concurred with the trial court’s assessment of AAA’s testimony as credible and ruled that discrepancies were trivial. It upheld the conviction and sentence.
Issues on Appeal to the Supreme Court
Umanito challenged his conviction on grounds of unreasonable delay in filing the complaint, alleged influence by AAA’s mother, and the victim’s inconsistent statements regarding their acquaintance, the sequence of events, and the locus of sexual acts.
Credibility, Delay, and Reasonable Doubt
The Supreme Court reiterated that delays alone do not extinguish criminal liability absent prejudice, and that credibility determinations rest on the trial court’s appraisal of demeanor. In consensual-versus-force disputes, minor inconsistencies do not automatically create reasonable doubt where force, threats, and the victim’s fear are shown.
Significance of Paternity and DNA Testing
Noting that AAA bore a child alleged to be Umanito’s, the Court emphasized that modern DNA analysis can conclusively determine parentage. A negative paternity result would cast reasonable doubt on the rape charge.
New Rule on DNA Evidence and Its Application
Under A.M. No. 06-11-5-SC (New Rule on DNA Evidence):
• The court may order DNA testing motu proprio.
• Requirements include existence of relevant biological samples, scientifically valid methods, and potential to yield new material facts.
• Guidelines cover custody, testing protocols (Sections 4–5), assessment of probative value (Section 7), and technical reliability (Section 8).
• Confidentiality (Section 11) and preservation (Section 12) of samples and results are mandatory.
Supreme Court Resolution and Remand
Finding paternity material to a fair adjudication, the Supreme Court
Case Syllabus (G.R. No. 172607)
Facts of the Case
- On July 15, 1989 at approximately 9:00 PM in Brgy. Daramuangan, Naguilian, La Union, the private complainant (AAA), an unmarried female aged over 12 but under 18, was accosted by Rufino Umanito, armed with a fan knife.
- The assailant forced AAA by threats and physical force: kisses, fondling of her breasts and stomach, dragging her into the Home Economics Building of Daramuangan Elementary School.
- Inside the building, Umanito undressed both himself and AAA, laid her on a bench, inserted his penis into her vagina, and afterwards threatened to kill her if she reported the incident.
- AAA managed to return to her grandmother’s home by around 1:00 AM. Six months later, her mother noticed an abdominal prominence, prompting AAA to reveal the rape and file a complaint in January 1990.
- Umanito denied leaving his home on the evening in question, claiming an alibi of working on family picture‐frame orders and asserted that his prior courtship of AAA had been unreciprocated.
Procedural History
- January 9, 1990: Criminal Complaint for rape filed against Umanito.
- 1995: Appellant was arrested when he sought a police clearance.
- February 11, 1997: Trial commenced at the Regional Trial Court (RTC) of Bauang, La Union, Branch 67.
- October 15, 1997: RTC found Umanito guilty beyond reasonable doubt of rape, imposed reclusion perpetua, and ordered P50,000 indemnity to AAA.
- July 7, 2004: Under People v. Mateo, appeal elevated to the Supreme Court and transferred to the Court of Appeals (CA) for intermediate review.
- February 15, 2006: CA affirmed RTC decision.
- October 26, 2007: Supreme Court resolution issued remanding case for DNA testing under the New Rule on DNA Evidence.
Issues on Appeal
- Whether the belated filing of the rape complaint (six months after the incident) created reasonable doubt.
- Whether discrepancies and inconsistencies in AAA’s testimony warranted discrediting her as a witness.
- Whether AAA pursued the complaint only at her mother’s prompting, calling into question the victim’s motive and credibility.
- Whether Umanito’s alibi defense was sufficiently proved to raise doubt.
- Whether DNA testing to determine paternity of AAA’s resultant child should be ordered to resolve doubt on appellant’s guilt.
Findings of the Regional Trial Court
- Credib