GR 119225; (July, 1996) (Digest)
G.R. No. 119225 July 26, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODRIGO ABUTIN y GIL, accused-appellant.
FACTS
On September 30, 1992, Lilian de la Cruz, while on her way home, was approached by her compadre, accused-appellant Rodrigo Abutin. He asked to talk privately, leading her to a nearby restaurant. Inside, he declared his love for her and, when she rebuffed him, suddenly placed a knife against her hip. Threatening to kill her if she caused a scene, he forcibly brought her to a motel room upstairs. There, he held the knife between his teeth while undressing, forcibly removed her clothes, and had carnal knowledge of her against her will. He detained her until morning, threatening her life if she reported the incident.
Lilian conceived from the assault. Fearful due to Abutin’s continuing threats, she did not immediately report the rape. She eventually resigned from work and went into hiding. On June 2, 1993, she disclosed the rape to her aunt and father, leading to a police report on June 4, 1993. Abutin was charged, convicted of rape by the trial court, and sentenced to reclusion perpetua. He appealed, challenging Lilian’s credibility, the delay in reporting, and claiming a prior romantic relationship.
ISSUE
Whether the trial court erred in convicting the accused-appellant of rape based on the credibility of the complainant’s testimony despite the alleged inconsistencies, delayed reporting, and the defense of a prior relationship.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the trial court’s assessment of witness credibility is accorded the highest respect and is generally binding on appeal unless it overlooked material facts. The Court found no such oversight. The alleged inconsistencies in Lilian’s testimony were minor and did not detract from the core narrative of forcible sexual intercourse through intimidation with a knife. The delay in reporting was satisfactorily explained by the appellant’s continuing death threats, which instilled pervasive fear, a valid reason for silence under jurisprudence. The defense of a prior amorous relationship was a matter of credibility, and the trial court correctly favored the complainant’s categorical denial over the appellant’s self-serving claim. The force and intimidation employed were proven, establishing all elements of rape. Thus, the conviction was upheld.