G.R. No. 119362 & 120269 June 9, 1997
The People of the Philippines, petitioner, vs. Ricardo O. Rabosa, respondent.

FACTS

Two informations for Rape were filed against Ricardo O. Rabosa, the father of the fifteen-year-old complainant AAA. The first information (Criminal Case No. Q-93-42335) alleged rape committed on or about February 14, 1993, by force and intimidation and with the use of a fan knife. The second information (Criminal Case No. Q-93-42336) alleged rape committed sometime during the last week of January 1993, also by force and intimidation with a fan knife. Upon arraignment, the accused pleaded not guilty. After a joint trial, the Regional Trial Court convicted Ricardo O. Rabosa on both counts, sentencing him to reclusion perpetua for each and ordering him to indemnify AAA P50,000.00 per case. The prosecution’s case relied primarily on the testimony of AAA. She testified that in the last week of January 1993, while she was washing dishes at home, her father pulled her into a room, turned off the light, forced her to lie down, poked a fan knife at her neck when she resisted, and succeeded in having carnal knowledge of her. She testified to a second incident on February 14, 1993, where, after she was forbidden from leaving the house to jog, her father turned off the light, poked a pointed object at her neck in the dark, pulled her down, and again had carnal knowledge of her. The accused appealed, arguing that his guilt was not proven beyond reasonable doubt, challenging the credibility of AAA’s testimony due to alleged inconsistencies with her sworn statements and the medico-legal report, the “unnatural” use of a knife given his moral ascendancy, her alleged lack of tenacious resistance and composure after the incident, and the medico-legal finding of healed lacerations.

ISSUE

Whether the trial court erred in convicting accused-appellant Ricardo O. Rabosa of the crime of rape despite the prosecution’s alleged failure to prove his guilt beyond reasonable doubt, specifically concerning the credibility of the complainant’s testimony.

RULING

The Supreme Court DISMISSED the appeal and AFFIRMED the trial court’s joint decision in toto. The Court held that the lone assignment of error, challenging the credibility of the complainant, was without merit. The Court found that the alleged inconsistencies in AAA’s testimony, her sworn statements, and the medico-legal notes were satisfactorily explained and did not diminish her credibility. The sworn statement dated March 9, 1993, specifically mentioned repeated assaults, including in January 1993. Inaccuracies in the medico-legal officer’s notes were deemed understandable given the victim’s traumatic state and the setting of the examination. The Court ruled that the use of a knife by the accused to threaten the victim was a natural means to ensure submission and constituted the necessary intimidation. The Court further held that the complainant’s submission and lack of intense physical resistance were justified by the continuing intimidation, the accused’s moral and physical ascendancy as her father, and his threats against her brothers. Her composed demeanor after the incident was not unusual, as different people react differently to traumatic situations. Finally, the Court ruled that the presence of healed hymenal lacerations did not negate the occurrence of rape, as these could have been from prior incidents, and a medical examination is not indispensable for a rape conviction if the victim’s testimony is credible. The conviction was sustained.