G.R. No. 110110 May 13, 1998
The People of the Philippines, plaintiff-appellee, vs. Inoferio Venerable, alias Porferio Venerable, accused-appellant.

FACTS

On January 21, 1992, an Information was filed charging Inoferio Venerable with the crime of rape committed against Clara Angcon on August 11, 1991, in Barangay Dobdob, Valencia, Negros Oriental. The accused pleaded not guilty. The prosecution presented complainant Clara Angcon and Dr. Fe L. Besario, the medico-legal officer who examined her. The defense presented the accused and his sister-in-law, Teresita Alabata Venerable.
The prosecution evidence established that on the evening of August 11, 1991, the accused arrived at the victim’s house while she was alone. After initially asking for water and food, he returned, held her forearms, pushed her to the kitchen, wrestled her to the floor, and forcibly had sexual intercourse with her. The victim testified that she was sexually assaulted four times that evening amidst her struggles, shouts, and cries for help. After the last assault, she managed to lock herself in the balcony when the accused fell asleep. She reported the incident and was medically examined by Dr. Besario on August 26, 1991, or fifteen days after the rape. The medical examination revealed a hematoma on her left arm but no vaginal lacerations or seminal fluids, which the doctor opined was understandable given the lapse of time.
The defense interposed denial and alibi. The accused claimed he was either at home resting after a trip or working on a family farm on the date in question, and later theorized that he and the victim were sweethearts and that the case was motivated by jealousy. His sister-in-law testified that he was in Malaunay stripping abaca from August 11 to 16, 1991. The Regional Trial Court found the accused guilty of rape and sentenced him to reclusion perpetua and ordered him to indemnify the victim P30,000. The accused appealed.

ISSUE

Whether the trial court erred in convicting the accused-appellant of the crime of rape despite his defenses of alibi and denial, and the alleged incredibility of the complainant’s testimony.

RULING

The Supreme Court affirmed the conviction with modification. The appeal was without merit. The Court found the complainant’s testimony to be straightforward, credible, and sufficient to establish the crime of rape. The defenses of alibi and denial were unavailing. For alibi to prosper, it must be shown that it was physically impossible for the accused to be at the scene of the crime; the accused’s inconsistent narrations and the proximity of his house (two kilometers away) failed to meet this requirement. His claim of a sweetheart relationship with the victim was unsupported by evidence and was a self-serving assertion.
The Court held that the absence of spermatozoa or seminal fluid in the medical examination, conducted fifteen days post-incident, did not negate rape, as a medical examination is not indispensable for a rape conviction. The victim’s credible testimony alone suffices. However, while the evidence showed four separate acts of rape, only one Information was filed charging a single offense; thus, only one conviction was proper. The civil indemnity was increased to P50,000.00 in line with prevailing jurisprudence. The decision of the trial court was AFFIRMED with the stated modification.