GR 72608; (June, 1993) (Digest)
G.R. No. 72608 June 30, 1993
People of the Philippines, plaintiff-appellee, vs. Julito U. Arnan, accused-appellant.
FACTS
On May 13, 1981, around midnight, Nora Ayado, a 20-year-old mother, was awakened by accused-appellant Julito U. Arnan sitting on her knees while her husband was away. She screamed, and her children awoke. Arnan pointed what appeared to be a pistol (later found to be a bent spoon) at her, covered her mouth, and warned her not to move or shout. As she struggled for the weapon, Arnan boxed her in the stomach, rendering her unconscious. Upon regaining consciousness, she found Arnan gone, her panties removed, and semen in her vagina. She immediately reported the incident to her sister-in-law and was medically examined the next day by Dr. Thelma B. Lamanilao, who found dead spermatozoa in her vaginal canal (less than 48 hours old) and signs of irritation consistent with sexual intercourse. Arnan claimed he and Nora were lovers and their sexual encounter that night was consensual, interrupted only when her nephew awoke. He alleged Nora filed the complaint to explain the incident to her husband. The defense presented witnesses: Jose Eludo, who claimed he saw Arnan and Nora holding hands and conversing prior to the incident, and Rogelio Grumo, who testified Arnan was with him from 5:00 a.m. on May 13 until 4:00 a.m. on May 14, contradicting Arnan’s own testimony that he went to Nora’s house at 8:00 p.m. on May 13.
ISSUE
Is the accused guilty of rape?
RULING
Yes, the accused is guilty of rape. The Supreme Court affirmed the conviction by the trial court but modified the civil indemnity from P5,000.00 to P30,000.00. The Court upheld the trial court’s assessment of Nora Ayado’s testimony as credible, consistent, straightforward, and sincere. It ruled that in rape cases, the lone testimony of the offended party, if credible, is sufficient to sustain a conviction. The Court found the defenses implausible: Nora’s scream for help contradicted the claim of a consensual tryst; the witness testimony about holding hands did not prove a sexual relationship; and the defense witnesses were contradictory (Arnan claimed he went to Nora’s house, while Grumo claimed Arnan never left). The Court also held that the absence of physical injuries does not negate rape, and the presence of dead spermatozoa was consistent with the medical findings. The prompt reporting and medical examination bolstered Nora’s credibility.