G.R. No. L-51084 December 26, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLITO DUNCA (DUNGCA) y FORNILOZA, defendant-appellant.

FACTS

The appellant, Carlito Dunca, was convicted of rape by the Court of First Instance of Laguna and sentenced to reclusion perpetua. The prosecution’s evidence established that on the night of December 21, 1977, the complainant, Nolena Catapang, was asleep in her home with her two young children when the appellant entered through a window, armed with a bladed weapon. He threatened to kill her and her children if she shouted, dragged her, and forcibly had sexual intercourse with her. She reported the assault to her husband the next morning, and they subsequently sought the assistance of the barrio captain and a medical examination.
The appellant admitted being at the complainant’s house that night but presented a contradictory version of events. He claimed that an ongoing consensual intimate relationship existed between them and that he was summoned to her house by a messenger, Ofelia Gaddi. He asserted that their encounter was amorous until interrupted by a child, prompting him to leave, and that the complainant later told him she filed the charge only because her husband threatened her.

ISSUE

Whether the evidence on record sufficiently established the appellant’s guilt for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction, finding the prosecution’s evidence credible and sufficient to prove guilt beyond reasonable doubt. The Court emphasized the trial court’s superior position to assess witness credibility, a finding entitled to great respect. The complainant’s testimony was found to be straightforward, consistent, and credible. Her failure to immediately shout for help or reveal her assailant’s identity was reasonably attributed to the appellant’s threats against her and her children’s lives.
In contrast, the appellant’s defense of a consensual relationship was deemed inherently incredible and uncorroborated. His claim that he was invited by the complainant via Ofelia Gaddi was riddled with contradictions; notably, Gaddi’s own testimony revealed she was unaware of any relationship between the parties, and the alleged message lacked specificity as to time. No other witnesses were presented to substantiate the alleged frequent meetings or affair. The Court modified the judgment by increasing the indemnity awarded to the complainant from P12,000.00 to P30,000.00. The decision of the trial court was affirmed with this modification.