G.R. No. 110823 July 28, 1997
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROCHEL TRAVERO, accused-appellant.

FACTS

On the night of October 3, 1992, thirteen-year-old Agnes Cuba was at a fiesta in Maslog, Danao City. After her cousin left her, she went with another cousin to buy ice water. While walking a few meters behind her companions, accused-appellant Rochel Travero, a college student, grabbed her from behind, pointed a pistol at her head, and threatened to kill her if she shouted. He dragged her to a dark area near a parked cargo truck, removed her shorts and underwear, and, while both standing, inserted his penis into her vagina against her will. Agnes felt pain and her vagina bled. After the act, appellant left on a motorcycle, taking her panty. She reported the rape to a policeman who arrived, was brought to the police station and a hospital, and was medically examined. The medico-legal findings showed lacerations and a broken hymen. The accused-appellant was charged and convicted of rape by the Regional Trial Court and sentenced to reclusion perpetua and ordered to indemnify the victim P40,000. Accused-appellant appealed, claiming the trial court erred in crediting the complainant’s testimony and argued that the sexual act was consensual as they were sweethearts.

ISSUE

Whether the trial court erred in convicting accused-appellant Rochel Travero of the crime of rape.

RULING

No. The Supreme Court affirmed the conviction. The Court applied the guiding principles in reviewing rape cases: accusations are easy to make but hard to disprove; the complainant’s testimony must be scrutinized with extreme caution; and the prosecution’s evidence must stand on its own merits. The Court found the complainant’s testimony credible and consistent with the medico-legal evidence. The alleged inconsistencies in her statements were on minor, inconsequential details and are considered badges of truth. The defense of sweetheart theory and consent was rejected. The Court emphasized that no young woman would fabricate a story of defloration and undergo the ordeal of a public trial unless motivated by a genuine desire to seek justice. The penalty of reclusion perpetua was affirmed, but the indemnity was increased to P50,000.00 in line with prevailing jurisprudence.