G.R. Nos. 115035-36; February 23, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PERCIVAL GECOMO y OSIT, accused-appellant.

FACTS

Accused-appellant Percival Gecomo was convicted by the Regional Trial Court of Manila for two counts of rape and sentenced to reclusion perpetua for each. The charges stemmed from incidents on June 20 and July 3, 1992. The prosecution, through complainant Regina Rapuzon, alleged that Gecomo, a co-worker, accosted her on both dates, poked a knife at her, and forcibly brought her to a hotel and then to his house, respectively, where he had carnal knowledge of her against her will. She testified to acts of violence, threats, and being rendered unconscious during the first assault.
The defense presented a contrary narrative, asserting that Gecomo and Rapuzon were sweethearts and that their sexual encounters were consensual. Gecomo claimed they were in a romantic relationship, a fact he attempted to corroborate with a witness. He argued that the complaints were fabricated after a lovers’ quarrel and that Rapuzon’s behavior after the alleged rapes, such as returning to work and not immediately reporting the incidents, was inconsistent with that of a victim.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that the accused committed rape through force, violence, or intimidation, or if the defense successfully established the existence of a romantic relationship rendering the sexual acts consensual.

RULING

The Supreme Court affirmed the conviction. The Court meticulously applied the principle that in rape cases, the credibility of the complainant is paramount. It found Regina Rapuzon’s testimony to be clear, convincing, and consistent with human experience. The Court held that her detailed account of the threats with a knife, the force employed, and her helplessness satisfactorily established the element of intimidation and lack of consent. The alleged inconsistencies in her testimony were deemed minor and did not affect her core narrative.
The Court rejected the defense of a sweetheart relationship as unsubstantiated. The alleged corroborating witness’s testimony was found to be unreliable and rehearsed. The Court emphasized that even if a prior relationship existed, it does not justify rape, and force or intimidation can still vitiate consent. The complainant’s failure to shout or escape immediately was not considered fatal, as the Court recognized the natural fear and intimidation instilled by a knife-wielding assailant. The trial court’s assessment of credibility was accorded great respect, and the defense failed to present clear and convincing evidence to warrant a reversal. The penalties and indemnities were thus sustained.