G.R. No. 130669 ; March 27, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILSON MITRA, accused-appellant.

FACTS

The prosecution’s evidence established that on May 23, 1996, in Urbiztondo, Pangasinan, the 14-year-old victim, Marites B. Eliang, was alone in her family’s kitchen. The appellant, Wilson Mitra, a neighbor, knocked and asked to borrow a bolo. When Marites allowed him to retrieve it, he seized her wrist, pointed the bolo at her, and threatened to kill her if she shouted. He then forcibly brought her to a bedroom, continued his threats, and proceeded to undress and sexually assault her while covering her mouth and brandishing the weapon. After the act, he threatened to kill her entire family if she reported the incident. Marites disclosed the rape to her parents a month later, on June 26, 1996, after learning Mitra had left for Manila. A medical examination revealed old hymenal lacerations consistent with prior sexual intercourse.
The defense presented a starkly different narrative. Mitra claimed he was elsewhere the entire day of the incident, constructing his house with companions. He alleged that Marites had a romantic infatuation with him, had written him a love letter, and had acted flirtatiously. He asserted that the accusation was fabricated after he rejected her advances and moved to Manila. Defense witnesses, including a 10-year-old relative, corroborated his claims of Marites’s affectionate behavior and the absence of electricity in her home, which explained her frequent visits to his residence to watch television.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt, specifically in light of the conflicting testimonies and the one-month delay in reporting the crime.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s clear, consistent, and candid testimony, which detailed the use of a deadly weapon and force, prevails over the denial and implausible imputation of motive by the defense. The Court found the victim’s account of being threatened with a bolo and warned against reporting to be natural and convincing. The delay in reporting was sufficiently explained by the appellant’s continuing threats against her and her family, which instilled fear, especially given his proximity as a neighbor. The medical findings, while not conclusive of recent intercourse, were consistent with her testimony regarding the timeline of the assault.
The defense’s theory of a romantic affair was deemed inherently incredible. The Court found it highly improbable for a 14-year-old provincial lass to fabricate a story of a violent rape, subject herself to the ordeal of a public trial, and persist in her accusations if they were untrue. The testimony of the child witness for the defense was also given scant weight, as it appeared rehearsed and was inconsistent with human experience. The aggravating circumstances of dwelling and use of a deadly weapon were duly appreciated. The penalty of reclusion perpetua was affirmed, and the award of moral damages was increased to P50,000.00, with an additional P50,000.00 as civil indemnity, in line with prevailing jurisprudence.