GR 254206; (August, 2023) (Digest)
G.R. No. 254206 , August 30, 2023
People of the Philippines, Plaintiff-Appellee, vs. Tito Pajarilla y Alas, Accused-Appellant.
FACTS
Accused-appellant Tito Pajarilla y Alas was charged with the rape of AAA on December 25, 2013. The prosecution’s version, as narrated by AAA, states that after returning home around 1:00 a.m. from a family gathering, her husband DDD left. AAA slept but was awakened by a man on top of her, later identified as accused-appellant, their neighbor. He punched her right shoulder, clamped her mouth, warned her not to shout, and proceeded to have carnal knowledge against her will. After the act, AAA sought help from neighbors, who alerted barangay officials and the police. Accused-appellant was arrested at his house. The prosecution presented AAA, CCC (father of AAA’s husband), and police officers who corroborated the report and arrest. The defense interposed denial and alibi, claiming accused-appellant was sleeping at his mother’s house and that the charge was fabricated by CCC due to a prior misunderstanding. The Regional Trial Court (RTC) found accused-appellant guilty beyond reasonable doubt of rape and sentenced him to reclusion perpetua without eligibility for parole, ordering him to pay damages. The Court of Appeals (CA) affirmed the conviction but modified the damages awarded.
ISSUE
Whether the Court of Appeals erred in affirming accused-appellant’s conviction for the crime of rape.
RULING
The Supreme Court denied the appeal and affirmed the CA Decision with modification. The Court held that all elements of rape under Article 266-A of the Revised Penal Code were proven beyond reasonable doubt: (1) accused-appellant had carnal knowledge of AAA, and (2) it was accomplished through force and intimidation. AAA’s testimony was found credible, straightforward, and consistent. The Court emphasized that the testimony of a rape victim, if credible, is sufficient to sustain a conviction. The defenses of denial and alibi were rejected for being weak and unsubstantiated, especially given accused-appellant’s admission that he lived only 20 meters away from AAA. The penalty of reclusion perpetua without eligibility for parole was affirmed. The Court modified the damages, awarding civil indemnity, moral damages, and exemplary damages of P100,000.00 each, with interest at 6% per annum from the finality of judgment until fully paid.