G.R. No. 119069 July 5, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO EXCIJA, accused-appellant.

FACTS

Accused-appellant Danilo Excija was charged with three counts of rape. This appeal concerns Criminal Case No. 6641 for the alleged rape on December 29, 1993. The prosecution’s evidence, primarily from the 17-year-old complainant Jocelyn Baylon, established that Excija lured her to his house under the pretext that her boyfriend wanted to see her. Once there, he forcibly dragged her to a room, locked the door, and poked a gun at her neck. Despite her resistance and shouts, he slapped her, undressed her, and had carnal knowledge against her will. After the act, he promised to marry her. The defense consisted of a general denial, with Excija submitting a counter-affidavit merely stating the allegations were “pure and simple lies.”
The Regional Trial Court found Excija guilty beyond reasonable doubt. Applying the Indeterminate Sentence Law, it sentenced him to an indeterminate penalty of 16 years, 5 months, and 11 days of reclusion temporal medium, as minimum, to 26 years, 8 months, and 1 day of reclusion perpetua medium, as maximum. It also ordered him to indemnify the victim P50,000. Excija appealed, arguing the trial court erred in giving credence to the complainant’s testimony and in convicting him despite alleged inconsistencies.

ISSUE

The core issue is whether the prosecution proved Excija’s guilt for the crime of rape on December 29, 1993, beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court found the complainant’s testimony to be clear, convincing, and consistent on material points, thereby satisfying the requisite quantum of proof for conviction. The defense of bare denial cannot prevail over the positive and categorical testimony of the victim, which was corroborated by her immediate reporting of the incident to her parents and the subsequent filing of the complaint. The alleged inconsistencies pertained to trivial details and did not undermine the essential fact of forcible sexual intercourse.
However, the Court corrected the penalty imposed. The crime was committed before the effectivity of Republic Act No. 7659. The applicable penalty under Article 335 of the Revised Penal Code was reclusion perpetua. The trial court erred in applying the Indeterminate Sentence Law, as it is not applicable to offenses punishable by reclusion perpetua. Furthermore, the Court held that reclusion perpetua, when imposed as a straight penalty, is indivisible. Therefore, the proper penalty is a straight penalty of reclusion perpetua. The Court also increased the civil indemnity to P50,000, consistent with prevailing jurisprudence. The decision of the trial court was modified accordingly.