G.R. No. L-73534. March 25, 1988.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FEDERICO ROSARIO, accused-appellant.

FACTS

The prosecution evidence established that on October 26, 1979, Guillerma Aquino, a 17-year-old student, entered her sister’s house to use the comfort room. As she finished, accused-appellant Federico Rosario suddenly appeared, holding a bolo. He threatened her with the weapon, covered her mouth, and ordered her to remove her underwear. When she resisted, he boxed her in the stomach, causing her to lose consciousness. Upon regaining consciousness, she felt pain and bleeding in her private parts. Rosario then warned her not to reveal the incident, threatening to kill her and her parents. Fearful, Guillerma kept silent until May 1980, when her father noticed her physical condition. After confrontation, she confessed. A medical examination confirmed she was seven months pregnant, leading to the filing of rape charges.
The defense consisted of alibi and denial. Rosario, then 61 years old, claimed he was elsewhere at the time, treating patients as a “hilot.” He asserted he had no involvement in Guillerma’s pregnancy. The trial court found the complainant’s testimony credible, convicted Rosario of rape, and sentenced him to reclusion perpetua with an order to indemnify the victim and support the offspring.

ISSUE

The sole issue is whether the trial court erred in convicting the accused of rape based on the complainant’s testimony, despite the defense of alibi and alleged inconsistencies.

RULING

The Supreme Court affirmed the conviction. The resolution hinged on the credibility of the complainant. The Court reiterated that in rape cases where only the victim and the accused can testify, the complainant’s testimony must be subjected to rigid scrutiny. If such testimony is credible, positive, and satisfies the court beyond reasonable doubt, it is sufficient for conviction. The trial court’s factual findings on witness credibility are generally accorded great weight, as it observed the witnesses’ deportment firsthand.
The Court found no reason to overturn the trial court’s assessment. Guillerma’s detailed account of the violent assault, including the use of a bolo and physical force rendering her unconscious, was deemed credible. Her initial silence due to threats against her and her family’s lives was understandable for a young, traumatized victim from a rural background and did not undermine her credibility. The medical finding of pregnancy corroborated her claim of carnal knowledge. Minor inconsistencies in her narration on collateral matters were expected and even indicated truthfulness, as a perfectly consistent story might suggest rehearsal.
The defense of alibi was inherently weak and uncorroborated. The Court also dismissed the argument about the accused’s advanced age, noting the evidence showed he overcame resistance by rendering the victim unconscious. Finding no ill motive for the complainant to falsely accuse a relative and former barangay captain, the Court upheld the judgment, modifying only the indemnity to P20,000.