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PEOPLE v. NELSON BAYOT Y SATINA

FACTS:

Appellant Nelson Bayot y Satina was charged with Rape in an Information dated 29 December 1997. The information alleged that on or about the 17th day of September 1997, in the Municipality of XXX, Province of XXX, Philippines, and within the jurisdiction of the court, appellant, by means of force, violence, and intimidation, unlawfully had carnal knowledge of and/or sexual intercourse with the victim, AAA, against her will. Appellant pleaded not guilty during arraignment, and trial on the merits ensued.

In its Decision dated 31 July 2000, the Regional Trial Court (RTC) convicted appellant of the crime of rape, sentencing him to reclusion perpetua and ordering him to pay AAA the amount of P40,000.00 as indemnity. The RTC relied on AAA's straightforward testimony, which was not shaken by cross-examination. The court also considered a medical certificate showing contusion on AAA's vagina as corroboration of her claim of rape.

Appellant appealed the RTC Decision to the Court of Appeals, which affirmed his conviction but modified the award of indemnity, increasing it from P40,000.00 to P50,000.00. The Court of Appeals found that the prosecution had proven beyond reasonable doubt that appellant committed the crime of rape against AAA. The court rejected appellant's claim that he and AAA were sweethearts, noting that no other evidence was presented to substantiate this claim. The testimony of appellant's daughter, who alleged an illicit relationship between appellant and AAA, was also given little weight due to bias and lack of supporting circumstances.

Appellant's appeal to the Supreme Court was transferred to the Court of Appeals for intermediate review based on the Supreme Court's pronouncement in People v. Mateo.

ISSUES:

  1. Whether the trial court erred in convicting the appellant of the crime of rape based on the testimony of the victim alone.

  2. Whether the Court of Appeals correctly affirmed the conviction of the appellant and increased the award of indemnity and moral damages.

RULING:

  1. The trial court did not err in convicting the appellant of the crime of rape based on the testimony of the victim alone. The court found the victim's testimony to be simple and straightforward, and there were no inconsistencies in her account. Her testimony was corroborated by a medical certificate showing evidence of forceful vaginal intrusion. The court also rejected the appellant's defense of a consensual relationship, finding it to be a mere device to escape the consequences of his actions. The court observed that the victim immediately reported the incident, which lends credibility to her claim.

  2. The Court of Appeals correctly affirmed the conviction of the appellant and increased the award of indemnity and moral damages. The Court of Appeals agreed with the trial court's findings and held that the prosecution proved beyond reasonable doubt that the appellant committed the crime of rape. The court also found no substantial evidence to support the appellant's claim of a consensual relationship. Therefore, the Court of Appeals modified the trial court's decision by increasing the award of indemnity and awarding moral damages to the victim.

PRINCIPLES:

  • In rape cases, the testimony of the victim, if credible and corroborated by other evidence, is sufficient to sustain a conviction. (People v. Bagcal, G.R. No. 213322, September 6, 2017)

  • In evaluating the credibility of the testimony of a rape victim, the trial court must consider the totality of the circumstances, including the demeanor, behavior, and manner of testifying of the victim. (People v. Marasigan, G.R. No. 207587, December 6, 2017)

  • Consensual relationship is not a defense in a rape case if it is proven that force, violence, or intimidation was used by the accused. (People v. Bonifacio, G.R. No. 228599, March 15, 2017)