GR 126648; (August, 2000) (Digest)
G.R. No. 126648 ; August 1, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANCISCO VILLANOS Y TUMAMANG, accused-appellant.
FACTS
The accused-appellant, Francisco Villanos, was convicted of rape by the Regional Trial Court of Makati and sentenced to reclusion perpetua. The information alleged that in the third week of December 1995, in Makati, Villanos offered a laced soft drink to the thirteen-year-old complainant, Danica Anna Torreno, rendering her unconscious, and then had carnal knowledge of her against her will. The prosecution evidence established that Villanos was living with the complainant’s family. On the evening in question, he offered coke to Danica and her siblings, causing them to feel dizzy and sleepy. Danica went to bed, felt Villanos on top of her, but could not resist due to weakness and lost consciousness. She awoke the next morning with vaginal pain. A similar incident occurred on January 7, 1996. In April 1996, Danica was found to be four to five months pregnant and subsequently revealed the rapes to her parents.
ISSUE
Whether the trial court erred in finding the accused guilty of rape beyond reasonable doubt despite the appellant’s claim that the complainant’s testimony was doubtful and contrary to human experience.
RULING
The Supreme Court affirmed the conviction. The Court held that the complainant’s testimony was credible and sufficient to establish guilt. The defense of alibi was weak, as it was not physically impossible for the appellant to have been at the crime scene. The Court emphasized that in rape cases, the testimony of the victim, if credible, is sufficient to sustain a conviction. The complainant’s detailed account of being drugged, losing consciousness, and the subsequent pain and pregnancy constituted clear evidence. The Court found no ill motive for the young complainant to falsely accuse the appellant. The delay in reporting was satisfactorily explained by the appellant’s threats and the complainant’s fear. The medical confirmation of pregnancy corroborated her claim. The penalty of reclusion perpetua was affirmed. The Court modified the damages, ordering the appellant to pay ₱50,000.00 as civil indemnity, ₱50,000.00 as moral damages, and an additional ₱25,000.00 as exemplary damages due to the aggravating circumstance of the victim’s minority and the use of a substance to subdue her.