G.R. No. 109140 March 8, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLAND TACIPIT, accused-appellant.

FACTS

On January 3, 1991, complainant Onelia Pamittan, a 17-year-old student, was at the house of her friend Eden Molina in Abulug, Cagayan. Accused-appellant Roland Tacipit, a married man known to Onelia, was also present. Upon leaving, the prosecution alleged that Tacipit restrained Onelia, held her hand and notebooks, and told her friends to go ahead, despite her pleas. The defense claimed they were sweethearts and left together willingly. It is undisputed they left together. On the way, in a coconut plantation, Tacipit wrestled Onelia to the ground, tore her T-shirt and skirt, pinned her hands, removed her shorts and panty, and ravished her. Afterward, he accompanied her near her home and threatened to kill her or her family if she reported it. Onelia immediately reported the rape to her uncle, Ernesto Marantan, who reported it to the barangay captain. The next day, she reported to the police, submitted her clothing for examination, and underwent a medical examination. An information for rape was filed against Tacipit. At trial, the defense claimed they were sweethearts since October 1990 and the act was consensual, presenting a ring engraved “Onelia” as proof. Onelia denied this, testifying she knew him to be married, and the ring did not fit her finger. The Regional Trial Court convicted Tacipit of rape and sentenced him to reclusion perpetua, moral damages, and costs.

ISSUE

Whether the trial court erred in giving credence to the prosecution’s theory and in convicting accused-appellant of rape despite the alleged failure to prove his guilt beyond reasonable doubt.

RULING

The Supreme Court affirmed the trial court’s decision. The Court found clear, convincing, and competent physical and testimonial evidence supporting guilt beyond reasonable doubt. The testimony of Onelia Pamittan was detailed and credible. Minor inconsistencies did not impair her credibility, especially in a rape case. The torn T-shirt, blood-stained shorts and panty, and detached and torn bra constituted physical evidence consistent with force and resistance, negating consent. Onelia’s immediate report to her uncle, the barangay captain, and the police were acts consistent with a victim seeking retribution, not with a consensual act. The defense of a sweetheart relationship was unfounded; the alleged proof (the ring) did not fit Onelia’s finger, and nothing indicated a special relationship. Even if true, such a relationship does not justify rape. The accused’s act of accompanying the complainant near her house was seen as a calculated move to ensure her silence, not a gesture of innocence. The prosecution evidence stood on its own merits and proved Tacipit’s guilt beyond reasonable doubt.