GR 137383; (November, 2000) (Digest)
G.R. No. 137383 -84, November 23, 2000
The People of the Philippines, plaintiff-appellee, vs. Reynaldo Velasquez y Ocampo, accused-appellant.
FACTS
The accused-appellant, Reynaldo Velasquez, was charged with two crimes stemming from events on January 1, 1997. In Criminal Case No. 97-0035, he was accused of rape. In Criminal Case No. 97-0036, he was charged with forcible abduction with rape. The victim, AAA, was 15 years old. The prosecution evidence established that in the morning, Velasquez, armed with what appeared to be a gun, accosted AAA in Makati, forced her into a taxi, and brought her to his grandmother’s house in Las Piñas. There, he raped her. Later that same day, inside a room in the same house, he raped her a second time. AAA eventually managed to escape, sought help from barangay officials, and Velasquez was apprehended.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for the crimes charged beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction but modified the legal characterization of the crimes. The Court found AAA’s testimony credible, straightforward, and consistent. Her detailed account of the abduction, the two sexual assaults, and her eventual escape was corroborated by the medical findings of an old hymenal laceration. The defense of denial and alibi was weak and unsubstantiated. The Court applied the doctrine that when a victim’s testimony is credible, it is sufficient to sustain a conviction for rape.
Regarding the criminal liability, the Court ruled that the first act constituted simple rape. For the second act, the Court clarified that it could not be separately punished as another complex crime of forcible abduction with rape because the abduction had already been consummated with the first rape. The subsequent detention was merely a continuation of the original forcible abduction. Thus, the second act was properly classified as a separate count of simple rape. The accused-appellant was therefore found guilty of two counts of rape, each punishable by reclusion perpetua. He was also ordered to pay civil indemnity and moral damages for each count.