GR 133605; (June, 2001) (Digest)
G.R. No. 133605 ; June 28, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENJAMIN BARRIAS, accused-appellant.
FACTS
Accused-appellant Benjamin Barrias was charged with the rape of private complainant Rosalinda Guerrero, then 15 years old, on April 27, 1995, in Naga City. The prosecution’s evidence established that on that date, around 9:00 a.m., the complainant went to Barrias’s house to buy mangoes. Barrias, armed with a bolo, dragged her inside, pushed her causing her to hit her head, threatened her with a fan knife, undressed her, and forcibly had sexual intercourse with her despite her resistance and pain. After the act, she fled, washed her bloodied clothes, but initially did not report the incident due to fear of Barrias’s threat to kill her. Her pregnancy, discovered months later, led to the revelation of the rape to her grandmother and subsequent reporting to the police. A medical examination confirmed hymenal lacerations and pregnancy. The complainant gave birth to a child who later died. The defense denied the rape, claiming the complainant visited to pick mangoes and later to borrow money, and suggested the charge was fabricated due to unpaid debts. The Regional Trial Court convicted Barrias of rape and sentenced him to reclusion perpetua, ordering him to pay moral damages and attorney’s fees.
ISSUE
Whether the trial court erred in convicting accused-appellant of rape, disregarding his defense, the alleged delay in reporting, and inconsistencies in the complainant’s testimony.
RULING
The Supreme Court DISMISSED the appeal and AFFIRMED the trial court’s conviction. The Court held that the trial court’s factual findings, including its assessment of the complainant’s credible and detailed testimony, are entitled to great respect. The alleged inconsistencies referred to trivial matters and did not affect her credibility. The delay in reporting was sufficiently explained by the complainant’s fear due to the accused’s death threats. The Court found no improper motive for the complainant to falsely accuse the appellant of a serious crime. The defense of denial could not prevail over the positive identification and credible testimony of the complainant. The penalty of reclusion perpetua was affirmed. The Court MODIFIED the damages, ordering accused-appellant to pay an additional P50,000.00 as civil indemnity, separate from the moral damages awarded by the trial court.