G.R. No. 100283 August 25, 1994
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LEOPOLDO TAYCO, accused-appellant.

FACTS

Accused Leopoldo Tayco was charged with the crime of rape committed on or about September 13, 1986, in Kalibo, Aklan. The Information alleged that while armed with a knife, he used violence and intimidation to have carnal knowledge of Jelly Inocencio, a 16-year-old high school student, against her will. A medico-legal report confirmed injuries consistent with sexual intercourse. The prosecution’s evidence established that on the evening of the incident, the accused and his friends were drinking at the victim’s house. After the victim’s mother left to buy medicine, Jelly went to the kitchen to urinate. The accused accosted her with a drawn knife, threatened to kill her if she shouted, dragged her to a coconut grove more than 50 meters away, and raped her. The victim did not immediately report the incident and went to her grandparents’ house. A physical examination the next morning confirmed the presence of spermatozoa in her vagina. The defense presented alibi and denial, claiming the accused left the house earlier and went home directly. The defense also presented witnesses to attack the victim’s moral character. The trial court found the accused guilty and sentenced him to reclusion perpetua and ordered him to pay civil indemnity.

ISSUE

The main issues raised on appeal were: (1) whether the trial court erred in giving credence to the testimony of the complainant and finding the accused guilty; and (2) whether the trial court erred in not finding that the case was filed to force the accused to marry the complainant.

RULING

The Supreme Court affirmed the judgment of conviction. The Court held that the trial court’s findings on the credibility of witnesses, especially in rape cases, are accorded great respect. The trial court found the victim’s testimony sincere and credible, and there was no evidence of ill motive to falsely accuse the accused. The Court ruled that the prosecution sufficiently established the elements of force and intimidation through the victim’s testimony about the knife threat and dragging. The victim’s failure to shout immediately was justified by fear. The Court also held that the victim’s failure to report the crime immediately and her family’s subsequent attempts to have the accused marry her did not undermine her credibility; such actions were viewed in light of Filipino customs seeking to restore honor and avoid scandal. The defense of denial and alibi was rejected as weak against the positive identification by the victim. The decision of the trial court was affirmed in toto.