G.R. No. 130684 ; February 5, 2004
PEOPLE OF THE PHILIPPINES, appellee vs. ARTURO MANAMBAY Y DIAMSON, appellant.

FACTS

The appellant, Arturo Manambay, was convicted by the Regional Trial Court of two counts of rape against his common-law wife’s younger sister, Jovita Salas. The prosecution evidence established that on December 8, 1996, appellant, while intoxicated and armed with a bolo, forced Jovita into a room and had carnal knowledge of her against her will. He threatened to kill her if she reported the incident. The following day, December 9, 1996, appellant again blocked Jovita’s exit, pointed a bolo at her, and raped her a second time under similar threats. Jovita’s medical examination revealed deep, healed hymenal lacerations consistent with recent sexual intercourse, corroborating her account.
The defense presented a denial and alibi. Appellant claimed he was watching television with others on the evening of December 8 and was at work the following morning. He alleged the charges were fabricated because Jovita wanted to separate him from her sister and because he had reported seeing Jovita with a boyfriend. His common-law wife, Anita, corroborated his alibi for December 8.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellant for two counts of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of the private complainant, Jovita Salas, to be credible, straightforward, and consistent. Her detailed narration of how the appellant used a bolo to intimidate her into submission on two successive days was deemed sufficient to establish the elements of rape through force and intimidation. The medical findings, which indicated non-virgin state and healed lacerations aged approximately 20 days prior to the examination, corroborated her claim of recent sexual violation. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction.
The defense of denial and alibi was rejected for being inherently weak and unsubstantiated. Alibi cannot prevail over the positive identification by the victim. The alleged motive for fabrication was deemed insufficient to overturn the consistent and credible testimony of the complainant. The Court also noted that the relationship between the appellant and the victim, where he exercised moral ascendancy as the partner of her sister, made the threats more credible and the victim’s submission more likely out of fear. The awards of civil indemnity, moral damages, and exemplary damages for each count of rape were affirmed as proper.