G.R. No. 121980 February 23, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GONZALO PENASO @ “LULU”, accused-appellant.

FACTS

The case involves four consolidated charges for rape filed by Basilisa Lacar, who was 15 years old at the time of the alleged incidents. The first information, docketed as Criminal Case No. 6775, specifically pertained to an alleged rape on November 16, 1989, at the house of the accused, Gonzalo Penaso. The complainant testified that she went to the accused’s house to borrow a book from his daughter, her classmate. The accused, upon opening the door, falsely stated his daughter was in the kitchen, forcibly pulled her inside, boxed her abdomen, and had carnal knowledge with her, causing her to bleed. He threatened to kill her if she reported the incident. She later gave birth to a child in July 1990.
The accused was acquitted in the three other cases (Criminal Cases Nos. 6787, 6788, and 6789) due to insufficient evidence. For the November 16 incident, the Regional Trial Court found him guilty of rape and sentenced him to reclusion perpetua, ordering him to pay P50,000 as indemnity and moral damages. The accused appealed, arguing the trial court erred in giving credence to the complainant’s testimony.

ISSUE

Whether the prosecution proved the guilt of the accused for the crime of rape in Criminal Case No. 6775 beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the complainant is paramount. The trial court’s assessment of witness credibility is accorded great respect, as it had the direct opportunity to observe their demeanor. The Court found no reason to deviate from this finding. The complainant’s detailed and candid testimony, which remained consistent even under cross-examination, was credible and sufficient to establish the elements of rape through force and intimidation. Her failure to immediately report the crime was satisfactorily explained by the accused’s threats against her life, which instilled fear. Delay in reporting, when reasonably explained, does not undermine credibility.
The defenses of denial and alibi, which were uncorroborated, cannot prevail over the positive identification and credible testimony of the victim. The Court, however, modified the damages awarded. Following prevailing jurisprudence, the award of P50,000 as civil indemnity is mandatory upon a finding of rape. Additionally, moral damages of at least P50,000 are automatically awarded in cases involving young victims aged 13 to 19. Thus, the accused was ordered to pay separate amounts of P50,000 as civil indemnity and P50,000 as moral damages.