G.R. No. 76002 April 22, 1992
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JULITO NAGUITA, defendant-appellant.

FACTS

The accused-appellant, Julito Naguita, was charged with the crime of rape in an information alleging that on August 8, 1981, in Tagoloan, Misamis Oriental, he willfully, unlawfully, and feloniously, through force and intimidation, attacked, assaulted, and boxed Purita Naguita and had sexual intercourse with her against her will and consent. He pleaded not guilty. The prosecution’s evidence, through witnesses Luther Ebabacol, Toribio Empasis, Dr. Cherissa R. Canete, and the complainant Purita Naguita, established that on the said date, while Purita was at her banana plantation, Julito Naguita suddenly approached her from behind, clasped her mouth, and boxed her on the diaphragm, causing her to fall unconscious. Witnesses Ebabacol and Empasis heard her shouts for help; Ebabacol saw the accused having sexual intercourse with Purita, and upon seeing him, the accused ran away. Purita regained consciousness at her house, noticing her vagina dripping with semen. Dr. Canete’s medical report showed abrasions and a contusion on Purita’s body. The defense, through Julito Naguita, Hermanito Neri, and Amelia Almaden, claimed that the sexual intercourse was consensual, alleging a long-standing love affair between the accused and the complainant that began in 1976. The Regional Trial Court found Julito Naguita guilty beyond reasonable doubt of rape and sentenced him to life imprisonment and ordered him to pay moral damages of P30,000.00.

ISSUE

The ultimate issue is whether the trial court erred in believing the prosecution’s version that the sexual intercourse was committed through force and against the complainant’s will, and in disbelieving the defense’s claim of a consensual sexual relationship.

RULING

The Supreme Court affirmed the trial court’s decision, subject to the modification that the penalty should be denominated as “reclusion perpetua” instead of “life imprisonment.” The Court upheld the trial court’s factual conclusions and credibility assessments, finding no reason to depart from the general rule of giving great respect to the trial court’s observations of witness demeanor. The Court rejected the appellant’s arguments, including his claim that the complainant’s silence during rebuttal constituted an admission of their alleged affair, noting that she had consistently maintained the act was against her will. The Court also found the defense’s story of a public illicit affair improbable and held that even a past consensual relationship is not a defense to rape if the specific act was committed by force. The Court found the complainant’s testimony credible and supported by medical evidence and the testimonies of eyewitnesses. The evidence sufficiently established the appellant’s guilt beyond reasonable doubt.