GR 129238; (February, 2001) (Digest)
G.R. No. 129238 . February 22, 2001.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REGALADO BURLAT y BANAWA alias “Dadong”, accused-appellant.
FACTS
On October 21, 1995, Judith Masayon, a 15-year-old minor, went to the store of accused-appellant Regalado Burlat to buy matches. Burlat, who was alone and drinking, suddenly grabbed her, pulled her into the kitchen, and threatened her with a knife. Despite her attempt to fight back with a burning piece of wood, Burlat overpowered her, boxed her, and proceeded to have carnal knowledge of her against her will. Judith lost consciousness and awoke later to find Burlat still present. He threatened to cut her tongue if she reported the incident, causing her to keep silent.
Several months later, in March 1996, Judith’s mother noticed her enlarged stomach. A medical examination confirmed Judith was pregnant, prompting her to finally disclose the rape. She executed a sworn statement, leading to the filing of charges. Burlat denied the accusation, claiming he was in a neighboring barangay delivering bamboo sticks at the time of the alleged incident, thereby interposing the defense of alibi.
ISSUE
Whether the trial court correctly convicted accused-appellant Regalado Burlat of the crime of rape.
RULING
Yes, the Supreme Court affirmed the conviction. The Court emphasized that the credibility of the complainant is paramount in rape cases, which are often committed in isolation. Judith’s detailed and consistent testimony, which included the use of a deadly weapon and specific acts of force and intimidation, was found credible and sufficient to establish guilt beyond reasonable doubt. The Court noted the absence of any ill motive for Judith to falsely accuse Burlat.
The defense of alibi was rejected as it could not prevail over Judith’s positive identification of Burlat as her assailant. The delay in reporting the incident, spanning nearly six months, was deemed justified due to the threats on her life, a common reaction among rape victims. The penalty of reclusion perpetua was upheld as the crime was committed with a deadly weapon. However, the civil indemnity was increased to P50,000.00, and an additional P50,000.00 in moral damages was awarded, in accordance with prevailing jurisprudence.