GR 123727; (April, 1999) (Digest)
G.R. No. 123727 April 14, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO GASTADOR y WAGAS, accused-appellant.
FACTS
The prosecution’s case, as presented by complainant Crisanta Balonzo-de Rosas, established that on May 1, 1994, appellant Antonio Gastador, an uncle of Crisanta’s common-law husband Marlito, visited their Quezon City home. After drinking liquor, appellant, upon Crisanta’s return in the evening, attacked her at knifepoint, punched her stomach causing her to lose consciousness, and then raped her. Crisanta testified to regaining consciousness to find appellant on top of her, performing the sexual act, and feeling vaginal bleeding. Fearing for her and her baby’s life, she initially did not report the incident to Marlito, who later noticed her distress and bloodstains. The following morning, she revealed the rape. A medico-legal examination conducted on May 3, 1994, confirmed she was in a non-virgin state but found no external signs of violence and negative for spermatozoa. The defense presented denial and alibi, claiming appellant was at his workplace in Pasig during the alleged incident and only visited the couple’s home the next day, May 2.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt, particularly in light of the medical findings and the complainant’s credibility.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the trial court’s assessment of witness credibility is accorded great respect, as it is in a better position to observe demeanor. The medical findings, while noting the absence of external injuries and spermatozoa, do not negate rape. The Court explained that the absence of extragenital injuries is inconsequential, as rape can be committed without leaving visible marks, especially when the threat of a knife is used to subdue the victim. The negative spermatozoa result is also not exculpatory, as its presence is not an element of the crime. The complainant’s detailed and consistent testimony, coupled with her natural hesitation to immediately report the crime due to threats, was found credible. The defense of alibi was weak and could not prevail over the positive identification by the victim. Thus, all elements of rape through force and intimidation were proven beyond reasonable doubt.