G.R. No. 129239 ; September 5, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PAUL LAPIZ, accused-appellant.

FACTS

On February 22, 1995, thirteen-year-old Ruby Geraldez was on her way to fetch a cow in Patrocinio, Claveria, Misamis Oriental. Her uncle, accused-appellant Paul Lapiz, suddenly emerged from bushes, grabbed her neck, and strangled her. When Ruby tried to shout, Paul boxed her in the abdomen until she fainted. Upon regaining consciousness, she found herself lying on the ground, naked from the waist down, with Paul on top of her. Despite her struggles, he succeeded in having carnal knowledge of her. After the act, Paul’s wife arrived and saw them both in a compromised state. She asked what was happening, recognized Ruby, cried, pushed Paul, and then left. Paul threatened to kill Ruby if she reported the incident. Ruby immediately reported the rape to the children of Paul’s brother and was medically examined the next day, with findings consistent with sexual intercourse.
The defense presented a starkly different narrative. Paul claimed he merely scolded and slapped Ruby for fighting with his niece, after which she ran away. He denied raping her and asserted he was with his wife the entire time at a nearby creek washing clothes. His wife corroborated his alibi, denying she witnessed any compromising scene or that she reacted as Ruby described.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt, hinging on the credibility of the complainant’s testimony against the defenses of denial and alibi.

RULING

The Supreme Court affirmed the conviction, upholding the trial court’s assessment of Ruby Geraldez’s credibility. The Court emphasized that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction. It found Ruby’s account of the attack, her resistance, and the immediate reporting to be clear, consistent, and convincing. The medical findings, while noting an absence of spermatozoa, corroborated her claim of recent sexual intercourse through noted lacerations.
The Court systematically rejected the defense’s arguments. It ruled that the wife’s alleged subdued reaction upon discovering them was not improbable, noting she was nine months pregnant and gave birth the next day, which could explain her initial shock and subsequent actions. The claim that the rape was impossible due to the wife’s proximity was dismissed, stating that rapists are often undeterred by the potential presence of others. The Court also found it logical for Ruby to seek immediate refuge at a nearby relative’s house rather than return to her distant guardian. The defenses of denial and alibi, unsupported by strong evidence, could not prevail over Ruby’s positive identification. The trial court’s decision was thus affirmed, with the modification that accused-appellant Paul Lapiz is ordered to pay Ruby Geraldez an additional P50,000.00 as civil indemnity, separate from the awarded moral damages.