G.R. Nos. 141773-76 January 22, 2003
People of the Philippines, plaintiff-appellee, vs. Rosendo Layoso @ Sendong, accused-appellant.

FACTS

Accused-appellant Rosendo Layoso was charged with four counts of rape under four separate Informations before the Regional Trial Court of San Carlos City. The complaints alleged that on October 22, 1998, November 18, 1998, December 14, 1998, and February 23, 1999, he had carnal knowledge of Marlene B. Nitoya, a minor aged 14 during the first three incidents and 15 during the fourth, through force, threat, and intimidation. The prosecution presented the testimony of Marlene, who detailed each incident where the accused-appellant, often smelling of alcohol, would grab her, threaten to kill her, and forcibly have sexual intercourse with her in secluded areas. Her parents and uncle corroborated her report of the rapes. Dr. Ma. Salome G. Romero testified that her physical examination of Marlene revealed healed hymenal lacerations consistent with penetration. The accused-appellant denied the charges, raising the defense of alibi for the specific dates and claiming the cases were filed in retaliation for a fistfight with Marlene’s cousin, Robert Nitoya. The trial court found him guilty beyond reasonable doubt of four counts of rape and sentenced him to reclusion perpetua for each count, plus civil indemnity and exemplary damages.

ISSUE

Whether the trial court erred in convicting the accused-appellant despite alleged inconsistencies in the testimonies of the prosecution witnesses and the incredibility of the complainant’s testimony.

RULING

The Supreme Court affirmed the conviction with modification. It held that the alleged inconsistencies in the testimonies of the prosecution witnesses (regarding the exact time, number of incidents, place of commission, and time of reporting) were minor and did not detract from the core fact of the rape. The Court emphasized the trial court’s superior position to assess witness credibility and found no reason to overturn its findings. The complainant’s testimony was deemed credible, straightforward, and consistent on the essential elements of the crime. Her failure to shout for help was justified by the accused-appellant’s threats to kill her. The defense of alibi was weak and could not prevail over the positive identification by the victim. The Court modified the damages awarded, ordering the accused-appellant to pay moral damages of P50,000.00 in addition to civil indemnity of P50,000.00 for each count of rape, and deleted the award of exemplary damages for lack of factual and legal basis. The penalty of reclusion perpetua for each count was affirmed.