G.R. No. 118918 September 27, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANGELITO TALLEDO, accused-appellant.

FACTS

Accused-appellant Angelito Talledo was convicted of rape by the Regional Trial Court and sentenced to reclusion perpetua. The prosecution established that on July 22, 1992, in San Miguel, Bulacan, the private complainant, Rosario Mariano, was alone at home. Talledo, who was intoxicated, arrived and refused to leave. After Rosario sought help from his relatives, his grandmother accompanied her back and assured her of her safety before departing. While Rosario was washing dishes, Talledo suddenly grabbed her, forced her inside, and during the struggle, her head bumped a wall causing her to become semi-conscious. He then raped her. Her cries were muffled by the rain. The medical examination confirmed injuries and the presence of sperm cells.
The defense did not deny sexual intercourse but claimed it was consensual, alleging they were lovers. On appeal, Talledo assailed the trial court’s credibility assessment, pointing to alleged inconsistencies in Rosario’s testimony regarding her activity when he arrived, her state of consciousness during the assault, her location during the washing of dishes, and her post-rape conduct, including his own boastful proclamation of the act.

ISSUE

Whether the trial court erred in convicting the accused-appellant of rape by giving full faith and credence to the testimony of the complaining witness despite alleged inconsistencies.

RULING

The Supreme Court affirmed the conviction. The Court meticulously addressed each alleged inconsistency and found them to be minor variances that did not undermine Rosario’s core narrative of forcible sexual assault. Her clarification that she had just woken up before washing dishes was reasonable. Her testimony about being semi-conscious during parts of the struggle was consistent with her ability to perceive events, as she explained she could still feel being carried. The claim that she was washing dishes outside was not incompatible with her statement that rain muffled her shouts, as the rain could have started later. Her act of seeking help from the accused’s relatives and resuming work outside after being assured of safety was a logical, if ultimately futile, attempt to handle the situation.
The Court emphasized that minor inconsistencies can be badges of truth, indicating an unrehearsed testimony. The accused’s drunken state explained his boastful proclamation after the rape. The trial court’s factual findings, including its superior position to assess witness demeanor, were accorded great weight. The Court modified the judgment by ordering the accused-appellant to pay moral damages of P30,000.00 to the victim, as mandated by Article 2219 of the Civil Code for the crime of rape.