G.R. Nos. 113692-93. April 4, 1997.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDWIN JULIAN, ALBERTO BUMANGLAG, ERNESTO MACALIPIS, and PEDRO DULDULAO, accused, EDWIN JULIAN, accused-appellant.

FACTS

On November 19, 1984, in Laoag City, beauticians Nelia Agtarap and Angeles Alonzo were forcibly abducted by four men, including appellant Edwin Julian. The group, using a car, was taken to a secluded area in Barangay 15, San Nicolas, Ilocos Norte. There, Nelia Agtarap was raped by Julian, Alberto Bumanglag, and Pedro Duldulao. The accused-appellant Edwin Julian was charged with forcible abduction with rape and three counts of rape under an amended complaint treated as the Information. After trial, the Regional Trial Court found Julian guilty as charged and sentenced him to four terms of reclusion perpetua.
Julian appealed, arguing the prosecution failed to prove his guilt beyond reasonable doubt. He claimed the victims’ testimonies were inconsistent and unreliable, particularly regarding the identification of the perpetrators and the sequence of events during the abduction and assaults. He also questioned the credibility of the witnesses, suggesting their narratives were improbable.

ISSUE

The core issue is whether the prosecution evidence, primarily the testimonies of the victims, is sufficient to prove the guilt of accused-appellant Edwin Julian for the crimes of forcible abduction with rape and multiple counts of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalties. The Court upheld the trial court’s assessment of the victims’ credibility, finding their testimonies to be clear, consistent, and convincing on material points. The Court emphasized that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction. Minor inconsistencies in the victims’ accounts regarding peripheral details do not undermine their credibility but rather indicate they were not rehearsed. The Court found the victims’ positive identification of Julian as one of the perpetrators to be reliable, given the circumstances and their opportunity to observe him during the prolonged ordeal.
However, the Court applied the doctrine that forcible abduction is absorbed by rape when the abduction was solely to commit rape. Consequently, Julian could not be separately convicted for forcible abduction with rape and the rape committed at the culmination of the abduction. The Court thus held him guilty of one count of rape for that initial act, plus two additional separate counts of rape committed subsequently during the same continuous captivity. The penalty was modified to three terms of reclusion perpetua. The award of indemnity to the victim was sustained.