GR 113513; (August, 1995) (Digest)
G.R. Nos. 113513-14 August 23, 1995
People of the Philippines vs. Jimmy Conte
FACTS
Accused-appellant Jimmy Conte, a former prisoner hired as a farm helper by Bernardo Crisostomo, was charged with rape and kidnapping with serious illegal detention. The prosecution evidence established that on the night of September 17, 1990, in the Crisostomo residence in Palawan, Conte entered the room of Gloria Crisostomo (Bernardo’s wife) and her two minor children. Armed with a homemade gun, he forcibly raped Gloria three times that night. He then detained Gloria and her children, later moving them to different locations in Puerto Princesa City over several days.
During their captivity, which lasted until their rescue by police on September 24, 1990, Conte repeatedly raped Gloria. A letter she managed to send led to their location and Conte’s arrest. The trial court convicted Conte of eleven counts of rape but acquitted him of kidnapping, finding the element of deprivation of liberty for the purpose of extorting ransom was not proven. Conte appealed, challenging his identification as the perpetrator and the credibility of the victims’ testimonies.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court found the testimonies of Gloria and her son Macris to be credible, consistent, and sufficient to establish Conte’s guilt. The defense of alibi and denial was weak and could not prevail over the positive identification by the victims, who knew Conte well as a live-in farmhand. The Court emphasized that in rape cases, the credibility of the complainant is paramount, and no woman would willingly undergo the ordeal of a public trial and recount such a humiliating experience unless motivated by a genuine desire to obtain justice.
Regarding the number of offenses, the Court held that the complaint, which alleged carnal knowledge “for several times,” was sufficient to sustain multiple convictions. Each act of sexual intercourse, proven during the trial as distinct and separate incidents, constitutes a separate crime of rape. The trial court correctly convicted Conte of eleven counts based on the evidence presented. The Supreme Court modified the civil indemnity, ordering Conte to pay P40,000.00 for each of the eleven counts of rape, consistent with prevailing jurisprudence. The acquittal for kidnapping was not reviewable as it had become final.
