G.R. No. 117217 December 2, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GENER DE GUZMAN y SICO, accused-appellant.

FACTS

On March 31, 1992, complainant Gilda Ambray was waiting for a ride home at a subdivision gate in Bacoor, Cavite. Accused-appellant Gener de Guzman, whom she recognized, offered her a tricycle ride. He instead took a different route, stopped near an unfinished house, and forcibly dragged her to a vacant lot. Despite her struggles and pleas, de Guzman threatened to kill her, slapped her, and succeeded in having carnal knowledge with her. After the incident, Gilda immediately reported the rape to her family and the police. De Guzman was charged with rape before the Regional Trial Court (RTC).
The RTC convicted de Guzman of rape and sentenced him to reclusion perpetua, ordering him to pay various damages. On appeal, de Guzman questioned the credibility of the complainant, arguing that her testimony was inconsistent and that her failure to shout immediately and her acceptance of the ride cast doubt on her story. He also challenged the award of exemplary and actual damages.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court held that the complainant’s testimony was credible, consistent, and candid. The detailed account of the rape, including her resistance and the threats made against her, established the essential elements of the crime through force and intimidation. The Court explained that the failure to shout immediately is not tantamount to consent, especially when the assailant threatens death. Her initial acceptance of the ride does not imply willingness to engage in sexual acts, and her subsequent conduct of immediately reporting the crime is consistent with that of a genuine victim.
Regarding the damages, the Court modified the RTC’s award. It upheld the award of moral damages and attorney’s fees but deleted the awards for exemplary damages and actual damages for loss of salary. The Court ruled that exemplary damages were not warranted absent any aggravating circumstance. It also found the claim for lost salary unsubstantiated by evidence. However, following prevailing jurisprudence, the Court increased the civil indemnity ex delicto to P50,000.00. The decision of the RTC was thus affirmed with modifications to the civil liabilities.