GR 126286; (March, 1999) (Digest)
G.R. No. 126286 March 22, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROGER VAYNACO, RONEO TABONES, ALLAN CAJIPE, and JUNIOR ONIOT DELIS (At Large), accused, ROGER VAYNACO, RONEO TABONES and ALLAN CAJIPE, accused-appellants.
FACTS
On September 26, 1994, May Anne Gabrito, a 15-year-old student, accepted an invitation from seven Divine Word University students to go to Sandy Beach Resort in Tacloban City. At the resort, she drank with them and was subsequently gang-raped by the seven students in a cottage starting at 7:00 p.m. After managing to leave, she was intercepted near the resort by a group of eleven teenagers, including appellants Roger Vaynaco, Roneo Tabones, and Allan Cajipe. They forced her to the adjacent Costa Brava beach resort, where, starting at 10:00 p.m., they successively raped her on a table, covering her mouth and manhandling her. She escaped after the assault. Medical examination confirmed the presence of spermatozoa and blood on her clothing.
ISSUE
Whether the conviction of the appellants for rape, based primarily on the testimony of the mentally disturbed victim, is valid and meets the standard of proof beyond reasonable doubt.
RULING
Yes, the conviction is valid. The Supreme Court affirmed the trial court’s decision, emphasizing that the credibility of the victim’s testimony is paramount. The Court held that when a victim asserts she was raped, she essentially states all that is necessary to prove the crime. The victim’s mental condition, diagnosed as a schizo-affective disorder and major depression, did not destroy her credibility. The Court reasoned that her ability to recall the material details of the traumatic event, despite her condition, bolstered her testimony. It noted that the trial judge’s active questioning was justified to fully appreciate the facts in a capital case and did not indicate bias. The Court further ruled that inconsistencies in her testimony, such as the exact number of assailants or minor details, are natural for a traumatized young victim and do not corrode the core of her narrative. The medical evidence corroborating sexual contact fortified her account. However, the Court modified the award by ordering each appellant to pay an additional P50,000.00 as civil indemnity ex delicto for each count of rape, in line with prevailing jurisprudence.