G.R. No. 85771 November 19, 1991
People of the Philippines vs. Bayani de los Reyes y Pustigo

FACTS

Accused-appellant Bayani de los Reyes was charged with Robbery with Rape. The information alleged that on October 15, 1986, in Mariveles, Bataan, appellant and an accomplice, while armed, robbed Emily Punzalan and Graciano Hernandez of cash and personal items. During the robbery, appellant, through force and intimidation, succeeded in having carnal knowledge of Emily Punzalan against her will. After trial, the Regional Trial Court found appellant guilty beyond reasonable doubt and sentenced him to reclusion perpetua.
The prosecution evidence established that on the evening of the incident, complainants Emily Punzalan and Graciano Hernandez were at an old pier. Appellant and his companion, pretending to be barangay tanods, accosted them. The accomplice pointed a gun at Hernandez while appellant held a dagger to Punzalan’s neck, pulling her to a secluded area. There, appellant ordered her to lie down and remove her clothing, then proceeded to have sexual intercourse with her. After the act, they took the victims’ personal belongings before fleeing.

ISSUE

The core issue is whether the prosecution proved appellant’s guilt for the complex crime of Robbery with Rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court meticulously reviewed the records and found the testimony of the rape victim, Emily Punzalan, to be credible, natural, and consistent. Her detailed account of the sexual assault and the subsequent robbery was corroborated by the testimony of Graciano Hernandez. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The defense of denial and alibi proffered by appellant was weak and uncorroborated, and could not prevail over the positive identification by the victims.
On the legal qualification of the crime, the Court held that the facts constituted the special complex crime of Robbery with Rape under Article 294(2) of the Revised Penal Code, as the rape was committed by reason or on the occasion of the robbery. The robbery and the rape were intertwined; the intimidation employed for the robbery facilitated the rape. The Court modified the penalty, however, by deleting the aggravating circumstance of nighttime, as it was not shown to have been deliberately sought to facilitate the crime. The indemnity awarded to the victim was also increased from P25,000 to P50,000 in line with prevailing jurisprudence. The decision of the trial court was thus affirmed with these modifications.