G.R. No. 127494. February 18, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIO MARABILLAS y CAÑEDA, accused-appellant.

FACTS

On the evening of January 12, 1992, fourteen-year-old Lourdes Arroyo was at her home in Bangar, La Union. While her parents were away, she went outside to tie a stray cow. The accused-appellant, Mario Marabillas, suddenly appeared, dragged her to a nearby riverbank, and pushed her to the ground. Despite her resistance, he forcibly removed her clothing, threatened to kill her if she screamed, and succeeded in having carnal knowledge of her. Lourdes immediately reported the rape to her mother, executed a police statement, and underwent a medical examination which confirmed fresh hymenal laceration and a contusion on her back. She later gave birth to a child as a result of the assault.
The defense presented a截然不同的 version. Marabillas claimed that he and Lourdes were sweethearts and that the sexual intercourse was consensual, even initiated by her. He testified about giving her a ring and visiting her multiple times. However, he provided no corroborating evidence, such as love letters or pictures, to substantiate this alleged romantic relationship. Lourdes firmly denied any such relationship, admitting only that she knew him as a frequent visitor of her aunt.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that the accused-appellant committed rape through force and intimidation, or if his defense of a sweetheart relationship and consensual sex is credible.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the complainant’s credibility, which is generally accorded great respect. Lourdes’ candid and consistent testimony, corroborated by the medical findings of fresh hymenal laceration and physical injury, firmly established the use of force. Her prompt reporting of the crime and the emotional difficulty she displayed in court reinforced the truth of her account.
The Court rejected the accused-appellant’s claim of a consensual relationship as a mere denial, unsupported by any credible evidence. It is highly improbable for a young barrio lass to fabricate a rape charge, undergo the ordeal of a public trial, and tarnish her own and her family’s honor unless motivated by a genuine desire for justice. The alleged sweetheart theory was deemed a transparent attempt to evade liability. The Court modified the damages awarded, ordering an additional P50,000.00 as civil indemnity ex delicto, which is mandatory upon a finding of rape, distinct from the moral damages already granted. The penalty of reclusion perpetua was sustained.