G.R. No. 119325 September 26, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SULPICIO CAPINIG y RANON, accused-appellant.

FACTS

The accused-appellant, Sulpicio Capinig, was charged with the rape of his 13-year-old niece, Trinidad Abriol. The prosecution evidence established that on the evening of February 2, 1992, in Aroroy, Masbate, Capinig accosted the victim on her way home. He dragged her to a cogonal area, poked a bolo at her neck to stifle her shouts, and forcibly had carnal knowledge of her twice. He then threatened to kill her if she reported the incident. Trinidad confided in a relative days later, prompting her mother to report the crime to authorities. A medical examination confirmed recent lacerations consistent with sexual intercourse.
On appeal, Capinig contended that the trial court erred in giving credence to the complainant’s testimony, which he alleged was incredible. He asserted that they were actually lovers and that the complaint was fabricated by the victim’s mother to end their relationship. He also questioned the delay in reporting the incident to the police.

ISSUE

Whether the trial court erred in convicting the accused-appellant of rape based on the credibility of the victim’s testimony.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, emphasizing that such factual findings are generally binding on appeal due to the trial judge’s unique position to observe demeanor. The Court found the victim’s testimony, given in a straightforward and consistent manner typical of a young, inexperienced barrio lass, to be credible and convincing. Her detailed account of the assault, including the use of a bolo and the threats, remained unshaken during cross-examination.
The Court rejected the defense of a love affair as implausible and unsupported by evidence. It ruled that the six-day delay in reporting the crime did not impair the victim’s credibility, as such hesitation is not uncommon for young rape victims, especially when threats are involved. The medical findings corroborated her claim. The legal logic is that the positive and categorical testimony of a rape victim, when credible, is sufficient to sustain a conviction. The presumption of innocence was overcome by proof beyond reasonable doubt. The Court modified the civil indemnity, increasing it from P30,000 to P50,000 due to the victim’s minority and her relationship to the appellant.