GR 114262; (December, 1999) (Digest)
G.R. No. 114262 December 22, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. QUIRINO QUIJADA y CIRCULADO, accused-appellant.
FACTS
On April 27, 1991, at dawn, Leonida Brina was waiting at a shed in Bohol for a bus. She was accompanied by Nerio Depalas. Accused-appellant Quirino Quijada arrived. When Leonida asked Nerio to fetch coffee, and Quijada also left, ostensibly for his bag, Quijada returned first. He embraced Leonida, and upon her resistance, boxed her, poked a knife at her neck, and pulled her away. He kicked her until she fell unconscious. Upon regaining consciousness, she discovered her panty removed, and that she had been raped. Her cash and wristwatch were missing.
Nerio, upon returning, saw Quijada board a bus. Leonida then emerged from near a teak tree and hysterically boarded the same bus, where she reported the rape and robbery to a policeman before fainting. Nerio later found a semen-stained panty at the scene. The medico-legal report confirmed recent sexual intercourse. The defense was mere denial, claiming Quijada was elsewhere during the fiesta and was mistakenly implicated after being on the same bus.
ISSUE
Whether the accused-appellant is guilty beyond reasonable doubt of the crime of rape.
RULING
Yes, the Supreme Court affirmed the conviction. The Court emphasized that the trial court’s assessment of the credibility of witnesses, particularly the victim, is accorded high respect. Leonida Brina’s clear, consistent, and credible testimony, corroborated by Nerio Depalas’s account and the medico-legal findings, sufficiently established the fact of rape. The defense of denial, uncorroborated and inherently weak, cannot prevail over positive identification. The Court found no ill motive for the victim to falsely accuse the appellant. The claim of poor lighting for identification was rejected, as the witnesses had conversed with the appellant under flashlight illumination minutes before the attack. Consequently, the prosecution proved guilt beyond reasonable doubt. The penalty of reclusion perpetua was affirmed, with modifications to the civil indemnity and moral damages.