G.R. No. 119217 January 19, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MIGUEL LUCBAN y SERVO, accused-appellant.

FACTS

Accused-appellant Miguel Lucban was convicted by the Regional Trial Court of Antipolo, Rizal, for the rape of his fifteen-year-old stepdaughter, Nenita Bentabal, and sentenced to reclusion perpetua. The prosecution evidence established that on the night of February 3, 1990, while Nenita’s mother was away, Lucban arrived home late. When Nenita opened the door, he pulled her, threatened her with a butcher knife, tied her hands to the bed, and had carnal knowledge of her against her will. Her younger sister was present but asleep. Lucban threatened to kill Nenita and her mother if she reported the incident. Nenita later revealed this was the third instance of rape, with two prior assaults occurring in January 1990. She reported the crimes to her mother the following day, leading to a police complaint.
The defense presented an alibi, claiming he was home with his wife and the children on the alleged night. He asserted he was later forcibly taken and maltreated by companions of Nenita. The medico-legal officer testified that Nenita’s physical findings were consistent with sexual intercourse occurring several weeks prior to examination. The defense highlighted Nenita’s delayed reporting and her affirmative answer when asked by defense counsel if she experienced “orgasm” during the assaults.

ISSUE

Whether the trial court erred in convicting the accused based on the complainant’s uncorroborated testimony and despite alleged inconsistencies.

RULING

The Supreme Court affirmed the conviction. The Court held that the testimony of a rape victim, if credible, is sufficient to sustain a conviction. The Court found Nenita’s testimony straightforward and credible. The delay in reporting the January incidents was sufficiently explained by the accused’s threats against her and her mother’s life, a common reaction for young victims under moral ascendancy and intimidation. The Court dismissed the significance of Nenita’s answer regarding “orgasm,” noting that as a 15-year-old with limited education, she likely did not comprehend the term’s technical meaning, and such a line of questioning was improper. The medico-legal findings, while not pinpointing the exact date, corroborated that sexual intercourse had occurred. The accused’s moral ascendancy as a stepfather and the use of a knife supplied the necessary force and intimidation. The award of civil indemnity was modified, ordering the accused to pay P50,000.00 as civil indemnity and another P50,000.00 as moral damages.