GR 114262; (November, 1999) (Digest)
G.R. No. 114262 . November 25, 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 for a bus at a shed in Bohol, accompanied by Nerio Depalas. Accused-appellant Quirino Quijada arrived. Leonida, feeling stomach pain, asked Nerio to fetch coffee from a nearby house. Quijada also left, ostensibly to get his bag. Upon returning alone, Quijada embraced Leonida. She resisted, but he boxed her, poked a knife at her neck, and dragged her across the road. He demanded she remove her panty; when she refused, he kicked her until she lost consciousness. She awoke to find her underwear removed, having been raped, and her wallet containing P150 and a Seiko watch missing.
Nerio, upon returning, found the shed empty. Using a flashlight, he saw Quijada board a bus. Leonida then emerged from near a teak tree and boarded the same bus. Nerio later found a semen-stained panty at the scene. On the bus, a hysterical Leonida reported the rape and robbery to a policeman before fainting. A medical examination confirmed recent sexual intercourse. Quijada’s defense was denial and alibi, claiming he was at a fiesta and merely a passenger on the bus where Leonida, in shock, reported the crime without initially identifying him.
ISSUE
Whether the prosecution proved beyond reasonable doubt that accused-appellant Quirino Quijada committed the crime of rape.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimony of Leonida Brina credible, consistent, and corroborated by other evidence. Witness Nerio Depalas’s account and the discovery of the stained panty supported her narrative. The medico-legal report confirmed sexual intercourse. The Court emphasized that rape is typically committed in isolation, making the victim’s testimony crucial, especially when given without motive to falsify. No improper motive was shown for Leonida or Nerio to frame the accused. Quijada’s claim of poor lighting for identification was rejected, as the witnesses had conversed with him for several minutes with flashlight illumination. His uncorroborated denial and alibi could not prevail over the positive identification and credible evidence presented by the prosecution. The trial court’s finding of guilt for rape was upheld, though the award of moral damages was increased to P50,000. The charge of robbery was not sustained, as the taking of property was not sufficiently proven as a distinct crime.