G.R. No. 120897 ; October 11, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SEVERO DAYUHA y DASO, accused-appellant.

FACTS

On September 26, 1993, In-In Nobelita Q. Rey, then 15 years old, and her companion Arlene Ampo took a bus driven by accused-appellant Severo Dayuha from Cagayan de Oro to Iligan City. Upon arrival at the terminal, the accused and the conductor prevented the two from leaving, calling them stowaways. After closing the bus windows, the accused spread a tent on the floor, forcibly removed In-In’s clothing, and, while armed with a piece of wood and covering her mouth, had carnal knowledge of her three times that night. The conductor similarly assaulted Arlene. The next morning, In-In proceeded to Zamboanga del Sur and reported the rape to her mother and the police.
The accused denied the allegations, claiming he alighted from the bus upon arrival, conversed with co-drivers, ate dinner, and later slept on a bench. He asserted that In-In and Arlene approached him for food money and that he only saw In-In crying because Arlene had left with her bag. He testified he slept separately and noticed In-In on the bus only the next morning when they departed for Aurora.

ISSUE

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

RULING

The Supreme Court affirmed the conviction. The trial court’s assessment of witness credibility is accorded great respect, as it had the direct opportunity to observe the witnesses’ demeanor. The victim’s testimony was found to be categorical, straightforward, and consistent, showing no ill motive to falsely accuse the appellant. The Court emphasized that it is highly improbable for a young woman to fabricate a story of rape, undergo medical examination, and endure a public trial unless motivated by a genuine desire for justice.
The accused’s arguments regarding the victim’s failure to immediately report the incident at the bus terminal and the alleged improbability of the crime occurring in a relatively public place were rejected. The Court ruled that the victim’s delay was sufficiently explained by the threat to her life, and the presence of people does not preclude the commission of rape, as rapists bear no respect for locale or time. The medical findings corroborated the victim’s account. Consequently, the positive identification by the credible victim prevails over the accused’s bare denial. The penalty of reclusion perpetua was upheld, with the Court modifying the damages to award an additional P50,000.00 as civil indemnity, in line with prevailing jurisprudence.