GR 121994; (October, 2000) (Digest)
G.R. No. 121994; October 18, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANGELES TEVES y TAPEL, accused-appellant.
FACTS
The accused-appellant, Angeles Teves, was convicted by the Regional Trial Court of rape and sentenced to reclusion perpetua. The prosecution evidence established that on August 22, 1993, the 15-year-old victim, Mary Jane Vargas, a cousin of the accused, was accompanied by him to Marbel. Upon their return to Lake Sebu that evening, they walked home as no transportation was available. While near a bridge, the accused declared his love, which the victim rejected due to their familial relationship. He then choked and kicked her, gagged her mouth with a towel, threatened her with a knife, and forcibly had carnal knowledge of her. The crime was witnessed by Jerry Dolan, who heard screams for help, saw the act in progress, and intervened, causing the accused to flee.
The defense presented a “sweetheart story,” claiming the victim had initiated intimate contact in a movie theater and that their interaction later that night was consensual, involving only embraces and kisses. He denied the rape and alleged the victim’s family ransacked his house. The trial court found the victim’s testimony credible and rejected the defense.
ISSUE
Whether the trial court erred in giving credence to the testimony of the victim, thereby convicting the accused-appellant of rape.
RULING
The Supreme Court affirmed the conviction, upholding the trial court’s assessment of credibility. The Court emphasized that the testimony of a young barrio lass, especially when accusing a close relative, is accorded great weight. It is contrary to human experience for a victim to fabricate a tale of rape against a family member, undergo the ordeal of a trial and medical examination, and subject her family to disgrace unless motivated by a genuine desire for justice. The alleged romantic relationship, even if true, does not negate rape, as force and intimidation can still be employed. The eyewitness account of Jerry Dolan corroborated the victim’s narrative. The Court found no ill motive for the victim to falsely testify. While affirming the penalty and civil indemnity, the Court modified the decision to award moral damages in the amount of P50,000.00, which is automatically granted in rape cases without need for further proof. The findings of fact of the trial court, having observed the witnesses’ demeanor, are entitled to the highest respect on appeal.