G.R. No. 107800 October 26, 1999
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLLY PARANZO, @ LORENZO PARANI, accused-appellant.

FACTS

The accused-appellant, Rolly Paranzo, was charged with the rape of Anna Liza Jacobe on November 13, 1991, in Rodriguez, Rizal. The prosecution presented the complainant, who testified that while sleeping, she was awakened by the accused on top of her, threatening her with a knife. She reported prior sexual abuses by the accused. Her grandmother, Rafaela Jacobe, testified regarding the complainant’s age and living situation. Dr. Jesusa Nieves, a medico-legal officer, confirmed the complainant was in a non-virgin state with a healed laceration and recent abrasion consistent with trauma within five days prior to the November 15, 1991 examination, corroborating the possibility of recent sexual intercourse.
During the trial, the complainant recanted her testimony and executed an affidavit of desistance, stating she lied due to a promise of monetary settlement from the accused, which was not paid. The defense presented the accused, who denied the charges and claimed he was working at a slaughterhouse during the alleged incident. He suggested the case was filed because the complainant’s mother was angered after he refused to lend her money.

ISSUE

Whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt despite the complainant’s recantation and affidavit of desistance.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the principle that a recantation, especially one executed after a conviction, is exceedingly unreliable and viewed with suspicion. The Court held that an affidavit of desistance does not automatically negate an earlier testimony given under oath, particularly in rape cases where such desistance is often procured through intimidation or financial consideration. The complainant’s admission that her recantation was motivated by an unfulfilled promise of monetary settlement severely undermined its credibility. Furthermore, the medico-legal findings provided strong physical corroboration of the complainant’s original account, as the abrasion indicated recent trauma consistent with the alleged rape date. The defense of alibi was rejected for being weak and uncorroborated; the accused failed to present witnesses from the slaughterhouse to substantiate his claim of physical impossibility. The trial court’s assessment of the original testimony as credible and convincing was thus upheld. The penalty of reclusion perpetua was affirmed, with the civil indemnity increased to P50,000.00 and an additional P50,000.00 awarded as moral damages, following prevailing jurisprudence.