GR 104628; (January, 1994) (Digest)
G.R. No. 104628 January 18, 1994
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROBERTO JACA Y DONAIRE, accused-appellant.
FACTS
The accused-appellant, Roberto Jaca y Donaire, was charged with the rape of Estelita Bentulan. The complaint alleged that on or about 3:00 AM on December 25, 1989, in Barangay Tinago, Inopacan, Leyte, the accused, by means of force, intimidation, and threats with a knife, had carnal knowledge of Estelita Bentulan against her will. Estelita, a married woman separated from her husband, was alone in her house after attending midnight mass. She was awakened by the accused covering her mouth and threatening her with a knife. She recognized his voice as that of a former suitor and regular customer. After a struggle of about thirty minutes, during which he pounded her thighs and squeezed her lower abdomen, he succeeded in raping her. Afterward, he identified himself as “Berto.” Estelita immediately reported the incident to the “Bantay Bayan” and the barangay captain. A medical examination the next day revealed a slight hematoma on her lower abdomen and a superficial wound on her toe, with no laceration or contusion of the vaginal wall. The accused admitted to having carnal knowledge but claimed they were lovers and that Estelita fabricated the rape charge after he refused her demand to marry her. The Regional Trial Court found him guilty of rape and sentenced him to reclusion perpetua and an indemnity of P20,000.00.
ISSUE
Whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt of the crime of rape.
RULING
The Supreme Court affirmed the trial court’s decision with modification. The Court held that the trial court’s findings on the credibility of the victim were entitled to great respect. The prosecution’s evidence, particularly the positive identification by the victim, her immediate reporting of the crime, and the medical findings corroborating her struggle, far outweighed the accused’s uncorroborated testimony. The Court found the accused’s claim of a consensual relationship illogical, as both parties were married to others, and he presented no witness to corroborate his story. The penalty of reclusion perpetua was proper for rape committed with a deadly weapon. However, the Court increased the indemnity from P20,000.00 to P40,000.00, in line with recent jurisprudence considering the bestiality of the crime and the moral damages due to the victim.