G.R. No. 128372 March 12, 2001
People of the Philippines vs. Remegio Dela Peña y Baguio

FACTS

The accused-appellant, Remegio Dela Peña, was convicted of raping his 11-year-old niece, Vilma Lapeña, in February 1989 in Laoac, Pangasinan. The prosecution alleged two incidents: first, when Vilma was sleeping in the appellant’s house and he placed himself on top of her, threatening to kill her if she made noise; and second, two days later, when appellant blocked her path, poked a knife at her neck, brought her behind his house, and forcibly had carnal knowledge with her. The victim did not immediately report the rape due to threats against her and her family. The case was filed in 1995 after the appellant, in a drunken state, boasted about the abuse, prompting the victim’s parents to confront her and subsequently report the crime.
The defense interposed denial and alleged ill motive, claiming the charge was fabricated because the victim’s family was angered by the appellant’s attempt to evict them from his land. The defense also attacked the victim’s credibility, citing her five-year delay in reporting and her later cohabitation with an older man. The trial court found the victim’s testimony credible and convicted the appellant of rape, sentencing him to reclusion perpetua and ordering him to pay moral damages.

ISSUE

Whether the trial court erred in convicting the accused-appellant of rape based on the victim’s testimony despite the delay in reporting and the lack of corroborative medical evidence.

RULING

The Supreme Court affirmed the conviction. The delay in reporting a rape, especially when the victim is a minor and the perpetrator is a relative who issued death threats, is not indicative of fabrication. The Court held that the victim’s fear, engendered by the appellant’s threats to kill her and her entire family, satisfactorily explained her silence for five years. The testimony of a rape victim, if credible, is sufficient to sustain a conviction. The Court emphasized that the victim’s clear, consistent, and unequivocal narration of how the appellant used a knife and force to accomplish his carnal desires constituted proof beyond reasonable doubt of the crime of rape through intimidation.
The absence of fresh physical injuries or a timely medical examination does not negate rape, as medical evidence is merely corroborative. The Court found the victim’s account of the forcible sexual intercourse, accompanied by pain and bleeding, to be credible. The penalty of reclusion perpetua was affirmed. The Court modified the damages, awarding P50,000.00 as civil indemnity and P50,000.00 as moral damages, both awarded automatically in rape cases without need of further proof.