G.R. No. 48362 February 28, 1990
PEOPLE OF THE PHILIPPINES, appellee, vs. FERNANDO RAFANAN, appellant.

FACTS

The appellant, Fernando Rafanan, was convicted of rape by the Court of First Instance of Nueva Ecija and sentenced to reclusion perpetua. The complainant, Filomena Angala, was a household helper for the appellant and his wife. She testified that on the night of February 9, 1974, while she slept on the ground floor, the appellant entered her mosquito net, pointed a firearm at her, rendered her unconscious through physical violence, and then raped her. She reported the incident to Mrs. Rafanan the next day but was implored to keep it secret. Filomena later left the household, discovered she was pregnant, and subsequently filed a formal complaint.
The defense interposed alibi, claiming the appellant was at a school function at the time of the alleged crime. The defense also challenged the credibility of Filomena’s account, arguing that the circumstances, such as the presence of the appellant’s young daughter nearby and the failure of Mrs. Rafanan to immediately notice the incident, made the rape improbable. The trial court rejected these arguments, giving full credence to the complainant’s consistent and straightforward testimony.

ISSUE

The core issue is whether the trial court erred in convicting the appellant of rape based on the complainant’s testimony and in rejecting the defense of alibi and claims of inherent improbability.

RULING

The Supreme Court affirmed the conviction. The Court reiterated the well-established doctrine that the testimony of a rape victim, if credible, is sufficient to sustain a conviction. The Court found Filomena’s narration of events to be clear, consistent, and convincing. Her immediate report to Mrs. Rafanan, her subsequent actions in leaving the household and formally reporting the crime, and her emotional demeanor during testimony all bolstered her credibility.
The defense of alibi was properly dismissed as weak and unsubstantiated, especially since the appellant failed to prove it was physically impossible for him to have been at the scene of the crime. The Court also held that rape can be committed even in places where others are present, as the presence of a young child does not negate the commission of the offense when force and intimidation are employed. The Court noted that the conception of a child was consistent with the timeline of the rape, further corroborating the complainant’s account. The penalty of reclusion perpetua was affirmed. However, the moral damages awarded to the victim were increased from P5,000 to P25,000 in line with prevailing jurisprudence. The order for the appellant to acknowledge and support the offspring was sustained, construed as an acknowledgment of filiation.