G.R. No. 112074 September 29, 1997
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIO GOMEZ, accused-appellant.

FACTS

The prosecution’s evidence established that on the night of February 15, 1991, Jennifer Onofre was at the Mati Central Elementary School compound with Benjie Amante. Amante assaulted her and attempted to rape her. Their struggle was interrupted by accused-appellant Mario Gomez, a security guard, who emerged with a flashlight and a carbine rifle. Gomez ordered Amante to leave but compelled Jennifer to stay at gunpoint. He then dragged her to a nearby hut where, through force and intimidation, he consummated the act of rape. Afterward, he allowed her to go home. Jennifer immediately reported the incident to the police, providing a detailed description of her assailant’s attire and firearm. Based on this description, the police apprehended Gomez at the school.
The defense presented a contrary version. Appellant testified that during his rounds, he discovered a couple engaged in sexual intercourse. As he approached to apprehend them, the man fled. He claimed he only saw the woman again when he was brought in for police questioning and was falsely identified. He asserted that the charge was fabricated because he had caught Jennifer and her boyfriend in a compromising situation.

ISSUE

Whether the trial court erred in convicting accused-appellant Mario Gomez of rape based on the credibility of the victim’s testimony.

RULING

The Supreme Court affirmed the conviction. The Court emphasized the settled doctrine that the trial court’s assessment of witness credibility is accorded great weight, as it had the direct opportunity to observe the witnesses’ demeanor. The victim’s testimony was clear, consistent, and credible. She provided a precise description of her assailant—a security guard in a long-sleeved fatigue uniform, with a green bandana, a flashlight, and a carbine rifle with a sticker on the butt—which led directly to Gomez’s apprehension. This description was corroborated by police testimony. The Court found no ill motive for Jennifer to falsely accuse Gomez and undergo the ordeal of a public trial. The defense of frame-up, alleging he was accused because he caught the victim with her boyfriend, was deemed inherently weak and unsupported by evidence. The Court held that the prosecution successfully proved all elements of rape under Article 335 of the Revised Penal Code: carnal knowledge was accomplished through force and intimidation, as the accused, armed with a rifle, instilled fear in the victim to submit to his will. The award of moral damages was sustained, but the separate award for attorney’s fees was deleted for lack of legal basis.