### Facts:
On August 26, 1997, in Quezon City, Philippines, Ella Magdasoc, an 11-year-old girl, was raped by Melencio Bali-Balita, the common-law husband of her mother. Bali-Balita assaulted Ella by first inserting his finger and then his private organ into her private part against her will and by means of force and intimidation. Ella later disclosed the incident to her sister, Miriam Gozun, and both reported the matter to their mother and eventually to the police, leading to Bali-Balita’s apprehension and the filing of a criminal case for rape against him.
Upon arraignment, Bali-Balita pleaded not guilty. The prosecution presented the testimony of the victim, a medico-legal officer, and the victim’s sister. Bali-Balita, in his defense, claimed an alibi, stating he was attending a wake at the time of the incident, supported by the testimony of Retilla Bali-Balita (Ella’s mother) and another witness.
The trial court found Bali-Balita guilty of the crime of consummated rape, basing its decision on the victim’s credible testimony corroborated by medical findings and sentenced him to death. The court ordered him to pay moral damages as well. Bali-Balita appealed the decision, arguing, among other things, that the medico-legal officer’s testimony contradicted the claim of forcible penetration and pointed out procedural issues regarding how his relationship to the victim was characterized in the charge against him.
### Issues:
1. Whether the guilt of Bali-Balita for the crime charged has been proven beyond reasonable doubt.
2. Whether the relationship of Bali-Balita to the victim as a qualifying circumstance was properly alleged in the information.
3. Whether the penalty of death was correctly imposed.
### Court’s Decision:
The Supreme Court affirmed the finding of guilt beyond reasonable doubt for the crime of rape but reduced the penalty from death to reclusion perpetua. The Court reasoned that although the testimony of the victim was consistent with the crime of rape, the information’s inadequate description of Bali-Balita’s relationship to the victim (not specifying it as a qualifying circumstance for the crime of rape) precluded the imposition of the death penalty.
### Doctrine:
1. In rape cases, the testimony of the victim, when found credible and consistent, is sufficient to sustain a conviction.
2. The qualifying circumstances elevating rape to its qualified form, such as the minority of the victim and the relationship to the offender, must be specifically alleged in the information to warrant the imposition of the death penalty. Not doing so limits the penalty to reclusion perpetua.
### Class Notes:
– **Statutory Rape**: The age of the victim being below twelve is sufficient to establish the crime of statutory rape, regardless of consent.
– **Qualifying Circumstances**: Specifically alleging the relationship between the offender and the victim and the victim’s age in the information is crucial for increasing the penalty to death.
– **Credibility of the Victim’s Testimony**: In cases involving sexual assault, the victim’s testimony can be deemed credible and sufficient for conviction, especially when corroborated by other evidence such as medical findings.
– **Doctrine of Alibi and Denial**: These defenses are generally viewed weakly compared to positive identification and credible testimony from the victim.
### Historical Background:
The case illustrates the stringent requirements for the pleading and proof of qualifying circumstances in prosecutions for rape under Philippine law, highlighting the procedural aspects that affect sentencing. The reduction of the penalty due to procedural lapses in the information underscores the judiciary’s adherence to due process and the importance of precise and accurate legal accusations, especially in capital cases.
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