GR 55346; (November, 1991) (Digest)
G.R. No. 55346 November 13, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JESUS SALDIVIA, accused-appellant.
FACTS
The accused-appellant, Jesus Saldivia, was charged with the rape of Conrada Sabay on July 2, 1973, in Libacao, Aklan. The prosecution evidence established that Saldivia entered the victim’s home, pinned her down while she was feeding her baby, and forcibly had sexual intercourse with her despite her physical resistance and shouts. The arrival of a neighbor, Agripina Icutan, caused Saldivia to flee. The victim immediately reported the assault to her husband and subsequently filed a complaint.
The trial court convicted Saldivia of rape but erroneously imposed an indeterminate sentence. On appeal, the Court of Appeals affirmed the conviction but correctly held that the proper penalty was reclusion perpetua. Pursuant to the rules, the appellate court certified the case to the Supreme Court for final review.
ISSUE
Whether the guilt of the accused-appellant for the crime of rape was proven beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction. The Court meticulously reviewed the records and found the testimony of the complainant to be credible, consistent, and sufficient to establish the elements of rape. Her detailed account of the force employed and her resistance was corroborated by the timely arrival of the witness, Agripina Icutan. The defense of alibi presented by the appellant was inherently weak and could not prevail over the positive identification by the victim.
The Court emphasized that in rape cases, the accused may be convicted solely on the credible testimony of the victim. The complainant’s conduct, including her immediate report of the incident, was consistent with that of a genuine victim. The alleged delay in filing the complaint was satisfactorily explained and did not impair her credibility. Consequently, the Court upheld the factual findings of the lower courts, which are accorded great weight and respect.
The penalty was corrected to reclusion perpetua, the single indivisible penalty for simple rape under the Revised Penal Code at the time. Furthermore, the Court awarded moral damages in the amount of P30,000.00 to the victim, recognizing the mental anguish and trauma inherent in such a crime. The decision of the Court of Appeals was affirmed with modification regarding the award of damages.