G.R. No. 128882 ; October 2, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. JOEL AYUDA, appellant.

FACTS

The prosecution’s evidence established that in the early dawn of May 4, 1993, private complainant Gloriphine Seno, 19 years old, was walking home with her sister from a benefit dance in Bayugan, Agusan del Sur. Appellant Joel Ayuda met them and, after the sister walked ahead, ordered Gloriphine to stop at a waiting shed. There, he pointed a .3516 caliber revolver at her right cheek, dragged her to a grassy area, and commanded her to undress. He then had carnal knowledge of her against her will. She could not shout due to the gun being continually poked at her. Afterward, he threatened to kill her and her family if she reported the incident. She immediately reported the rape to the police and was medically examined, with the findings confirming recent sexual intercourse and physical injuries consistent with force.
The appellant, pleading not guilty, denied the charge and claimed that Gloriphine was his sweetheart and that their sexual encounter was consensual. The Regional Trial Court convicted him of rape under Article 335 of the Revised Penal Code and sentenced him to reclusion perpetua, ordering him to pay ₱30,000.00 in civil indemnity. Appellant appealed, challenging the credibility of the victim’s testimony and the sufficiency of the prosecution’s evidence.

ISSUE

Whether the prosecution has proven the guilt of appellant Joel Ayuda for the crime of rape beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found that all elements of rape through force and intimidation were proven beyond reasonable doubt. The victim’s testimony was clear, consistent, and credible, detailing how the appellant used a gun to intimidate her and force her into sexual intercourse. The medical certificate corroborated her account, showing injuries such as a lacerated labia minora and hymenal laceration. The Court emphasized that in rape cases, the credibility of the complainant is paramount, and her positive identification of the appellant, coupled with the medical evidence, prevails over the appellant’s bare denial and implausible sweetheart defense. The claim of a romantic relationship was unsupported by evidence and could not negate the clear demonstration of force and intimidation.
The Court modified the damages awarded. Following prevailing jurisprudence, the civil indemnity was increased from ₱30,000.00 to ₱50,000.00. Moral damages of ₱50,000.00 were also awarded without need of further proof, given the mental anguish suffered by the victim. Furthermore, because the rape was committed with the use of a deadly weapon as alleged and proven, exemplary damages of ₱25,000.00 were granted. The penalty of reclusion perpetua was affirmed.