GR 108743; (March, 1996) (Digest)
G.R. No. 108743 . March 13, 1996.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARNALDO B. DONES @ “NENE”, accused-appellant.
FACTS
The accused-appellant, Arnaldo B. Dones, a quack doctor, was convicted of rape by the Regional Trial Court. The victim, 14-year-old Marialina Ruaya, was brought to his clinic by her parents for treatment on July 8, 1991. After diagnosing her with a serious ailment, appellant isolated her from her mother by claiming a devil might enter her body if she stayed. Left alone with Marialina, he used this fabricated threat of Satanic possession to intimidate her. In the early morning of July 9, he forced her to lie down, covered her mouth to prevent her from shouting, and had carnal knowledge of her against her will.
Marialina did not immediately report the rape due to fear and shame, compounded by appellant’s continued warnings about Satan. She was only able to leave the clinic the following afternoon after her mother insisted. The defense was a simple denial, claiming the charge was fabricated because the victim’s family owed him money for medical services.
ISSUE
The core issue is whether the prosecution proved the appellant’s guilt for the crime of rape beyond reasonable doubt, particularly in light of the defense’s challenge to the victim’s credibility and the absence of immediate disclosure.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the victim’s testimony as credible, natural, and consistent with human experience. It emphasized that an accusation of rape is difficult to make, and a young victim’s initial silence, when explained by fear, intimidation, and shame, does not undermine her credibility. In this case, the appellant’s exploitation of his position as a healer and his use of superstitious beliefs to instill fear constituted the intimidation necessary for rape.
The Court found the defense of denial inherently weak against the positive, categorical, and consistent testimony of the victim. The penalty of reclusion perpetua was correctly imposed under Article 335 of the Revised Penal Code. The Court, however, modified the damages, ordering the appellant to pay the victim P50,000.00 as civil indemnity, in line with prevailing jurisprudence.