G.R. No. 120235 September 30, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALEX DE LOS SANTOS y SANTOS, defendant-appellant.

FACTS

On September 15, 1993, around 3:00 p.m., 15-year-old Rubilita Ganto was at her home in Kalookan City preparing a school project when her neighbor, accused Alex de los Santos, barged in. He pointed an icepick at her neck, threatened to kill her if she shouted, and forced her to her bedroom. Despite her crying and begging, he pressed the icepick deeper, scraping her skin. Out of fear for her life, she undressed and lay down. Accused then undressed, lay on top of her, and while continuing to press the icepick to her neck, inserted his penis into her vagina. The act lasted five to ten minutes. Afterward, he ordered her to dress and left. Her grand uncle, Marvin Sumlin, found her crying and trembling at 6:00 p.m., and she reported the rape. The barangay officials arrested the accused. A medico-legal examination on September 16, 1993, revealed a healing deep hymenal laceration compatible with recent sexual intercourse. The accused denied the charge, claiming he was drinking beer elsewhere and later watched TV at the victim’s house, and alleged the charge stemmed from a feud between the victim and another person’s wife. The Regional Trial Court convicted him of rape and sentenced him to reclusion perpetua, ordering him to pay moral and exemplary damages.

ISSUE

Whether the evidence presented by the prosecution is sufficient to convict the accused of rape beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction with modification. The Court found the testimony of the victim, a young student, credible and straightforward. Minor inconsistencies in her testimony regarding her school schedule and the absence of documented extragenital injuries from the icepick were deemed inconsequential and even enhanced her credibility by negating any suspicion of a rehearsed testimony. The victim’s failure to shout for help was justified by the intimidation and threat to her life posed by the icepick; physical resistance is not required when intimidation is present. The defense of denial was deemed weak against the victim’s positive identification. The Court modified the damages awarded: the accused is ordered to pay the victim P50,000.00 as civil indemnity and P50,000.00 as moral damages. The award of exemplary damages was deleted for lack of legal basis. The penalty of reclusion perpetua was affirmed.