FACTS:
This case involves the review of a decision by the Court of Appeals, affirming with modification the judgment of the Regional Trial Court (RTC) finding appellants Roberto Gingos and Nestor Margote guilty of two counts of rape. The prosecution's sole witness, AAA, testified that on October 28, 1999, she was grabbed by Margote as she was leaving a neighbor's house and was forcibly taken inside the house where Gingos lived with Margote. In the house, the appellants forced AAA to lie down, undressed her, and took turns in raping her. After the assault, AAA was warned not to report the incident under threat of physical harm. However, three days later, she mustered the courage to tell her mother, who then accompanied her to file a complaint against the appellants.
The appellants' defense consisted of denial and alibi. They claimed that they were not in the area where the rapes were alleged to have taken place on the night of the incident and presented witnesses to corroborate their alibi. Despite their defense, the trial court found the appellants guilty beyond reasonable doubt of rape and sentenced them to life imprisonment.
The case was elevated to the Court of Appeals, which affirmed with modification the decision of the trial court and imposed the penalty of two reclusion perpetua on each appellant for the two counts of rape. The appellants raised as their sole assignment of error the failure of the trial court to appreciate their testimony and that of their corroborating witness, arguing that the charges against them were fabricated.
The Supreme Court affirmed the decision of the Court of Appeals, emphasizing the crucial role of the complainant's credibility in rape cases. Once found credible, the complainant's lone testimony is sufficient to sustain a conviction. The Court also gave great respect to the trial court's findings on the credibility of witnesses. A witness who testifies in a categorical, straightforward, spontaneous, and consistent manner is considered credible.
ISSUES:
-
Whether the testimony of the victim is credible and sufficient to sustain a conviction.
-
Whether the defense of alibi can overcome the positive identification of the accused.
-
Whether the testimony of AAA, the victim, is credible.
-
Whether the alibi and denial of the appellants can prevail over AAA's positive identification.
-
Whether the failure of AAA to shout for help or resist the sexual advances of her rapists is tantamount to consent.
-
Whether the non-presentation of a medical certificate is fatal to the prosecution's case.
RULING:
-
The testimony of the victim is credible and sufficient to sustain a conviction. Jurisprudence has established guidelines in scrutinizing the trustworthiness of a witness, such as the respect given to the findings of the trial court on credibility, the consistency of the witness's testimony, and the spontaneous and straightforward manner of the witness's narration. In this case, the trial judge found the victim's declaration to be very credible and detailed, without artifice. The judge also noted that the victim had no reason to charge the accused if she was not sexually molested. Therefore, her positive identification of the two accused is not overcome by their alibi defense, which the judge considered to be an afterthought.
-
The Supreme Court affirms the finding of the trial court that AAA's testimony is credible. No ill will on her part has been shown that might have impelled her to falsely charge the appellants with rape if it were not true.
-
The court rules that a categorical and positive identification of the accused, without any showing of ill-motive on the part of the eyewitness, prevails over alibi and denial. The appellants' claim of alibi is weak and cannot prevail over AAA's positive identification.
-
The court clarifies that the failure of AAA to shout for help or resist the sexual advances of her rapists does not imply consent. Physical resistance need not be established in rape when threats and intimidation are employed, and the victim submits due to fear.
-
The court states that a medical certificate is not indispensable to prove the commission of rape. The victim's credible testimony alone is sufficient to convict the accused of the crime.
PRINCIPLES:
-
Once a witness is found credible, her lone testimony is sufficient to sustain a conviction.
-
The findings of the trial court pertaining to the credibility of witnesses are entitled to great respect and even finality.
-
A witness who testifies in a categorical, straightforward, spontaneous, and frank manner, and remains consistent on cross-examination, is deemed credible.
-
No woman, especially one of tender age, would concoct a story of defloration and go through the process of trial, examination of her private parts, and public humiliation unless she has actually been the victim of abuse.
-
Credibility of a witness can be determined by examining the presence or absence of ill will or motive.
-
A categorical and positive identification of an accused prevails over alibi and denial unless substantiated by clear and convincing evidence.
-
Physical resistance is not required in rape cases if the victim submits due to fear, threats, or intimidation.
-
A medical certificate is not indispensable to prove the commission of rape; the victim's credible testimony alone can suffice.