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 alleged that on the night of February 9, 1974, while she slept on the ground floor, the appellant entered her mosquito net, threatened her with a firearm, rendered her unconscious by physical force, and then raped her. She reported the incident to the appellant’s wife the next day and later left the household. Her subsequent pregnancy and the birth of a child were presented as corroborative evidence.
The appellant denied the accusation and interposed the defense of alibi, claiming he was at a school function at the time of the alleged crime. He also challenged the credibility of the complainant’s testimony, the proof of the child’s birth, and the trial court’s refusal to allow him to present additional witnesses.

ISSUE

The core issue is whether the trial court erred in convicting the appellant of rape based on the evidence presented.

RULING

The Supreme Court affirmed the conviction. The Court meticulously addressed the appellant’s arguments, applying settled legal principles. On credibility, the Court upheld the trial court’s assessment, emphasizing that the complainant’s straightforward and consistent testimony, coupled with her immediate report to the appellant’s wife and subsequent actions, carried the weight of truth. The Court found her account of resistance and the threats made by the appellant to be credible and sufficient to establish force and intimidation.
The defense of alibi was correctly rejected for being weak and unsubstantiated, especially in light of the positive identification by the complainant. The Court also ruled that the trial court did not commit a grave abuse of discretion in limiting the presentation of witnesses, as the proposed testimonies were deemed cumulative or irrelevant. Regarding the child’s paternity, the Court applied the legal presumption that a child conceived during or within 120 days of a rape is the offspring of the perpetrator. This presumption, coupled with the conception timeline matching the alleged crime, sufficiently established filiation for the purpose of the support order.
The penalty of reclusion perpetua was affirmed as proper. However, the Court increased the moral damages from P5,000 to P25,000 in line with contemporary jurisprudence to provide more adequate compensation for the victim’s suffering. The order for the appellant to acknowledge and support the child was sustained, clarified as a mere recognition of filiation given his married status. The decision was affirmed with the modification on damages.