GR 119956; (August, 1999) (Digest)
G.R. No. 119956 . August 5, 1999.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CRESENTE NAPIOT, accused-appellant.
FACTS
Accused-appellant Cresente Napiot was charged with the rape of Rosario B. Naves on August 15, 1976, in Barangay Dongos, Dinas, Zamboanga del Sur. The information alleged he used violence, force, and intimidation to have carnal knowledge against her will. The Regional Trial Court found him guilty and sentenced him to reclusion perpetua and indemnity of P40,000.00. Rosario testified that on the evening of August 15, 1976, after helping with the corn harvest, accused-appellant (her brother-in-law) offered to take her home. On the way, he forced her to a grassy area, threatened to kill her, boxed her, ripped her pants, and had sexual intercourse with her. She reported the incident the next day, executed a sworn complaint on August 17, 1976, and was medically examined, with findings consistent with recent sexual intercourse and physical injuries. Accused-appellant was not apprehended until September 27, 1993. He pleaded not guilty and interposed the defense of alibi, claiming he was in Pamantakan, Bukidnon, on the date of the incident. He alleged the charge was fabricated due to family resentment over his marriage and a belief that his mother caused the death of Rosario’s brother. He also claimed he left because he discovered his wife’s infidelity. His mother corroborated parts of his testimony.
ISSUE
Whether the prosecution proved beyond reasonable doubt that accused-appellant committed rape.
RULING
The Supreme Court affirmed the conviction. The Court found Rosario’s testimony credible, straightforward, and consistent. The medical certificate corroborated her account of a recent sexual assault. The defense of alibi was weak and could not prevail over the positive identification by the victim. The long delay in reporting and filing the case was sufficiently explained by the victim’s fear and the accused’s flight. The Court modified the award of damages, increasing the civil indemnity to P50,000.00 and awarding an additional P50,000.00 as moral damages. The penalty of reclusion perpetua was affirmed.