G.R. No. 134074-75, January 16, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EMILIANO DURANAN, a.k.a “Kalbo”, accused-appellant.

FACTS

Accused-appellant Emiliano Duranan was convicted by the Regional Trial Court of two counts of rape against Nympha Lozada, a 25-year-old woman described as retarded. The incidents allegedly occurred on March 7 and 8, 1994, in Quezon City, where both the appellant and the complainant’s family resided in the same apartment. For the first incident, the prosecution alleged that appellant dragged complainant into a common bathroom, threatened her, and had carnal knowledge against her will. The second incident purportedly occurred in appellant’s room, where he again forced himself on her. The crimes were reported after the complainant’s mother noticed her injuries.
The prosecution presented the complainant, her mother, and a medico-legal officer. The medical examination revealed a bruised lower lip, congested labia minora, and a shallow healing hymenal laceration, which the doctor concluded was compatible with recent loss of virginity. The defense, in its demurrer to evidence which was denied, presented an alibi, claiming appellant was at work during the first alleged incident and that the charges were fabricated due to a prior dispute over rent.

ISSUE

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

RULING

The Supreme Court affirmed the conviction. The Court found the complainant’s testimony credible, straightforward, and consistent. It held that the testimony of a rape victim, if credible, is sufficient to sustain a conviction. The Court gave weight to the fact that the complainant, despite her mental condition, provided a coherent and unwavering account of the traumatic events. Her immediate report to her mother and the subsequent medical findings corroborated her allegations. The medico-legal certificate, indicating recent loss of virginity and physical injuries, provided strong physical corroboration.
The defense of alibi was rejected as inherently weak and unsubstantiated by clear and convincing evidence. The Court emphasized that alibi cannot prevail over the positive identification by the victim. The elements of rape—carnal knowledge through force or intimidation—were duly established. The force was evident from appellant dragging the complainant and holding her, while intimidation was present through his threats. The Court modified the damages, increasing the civil indemnity to P100,000.00 (P50,000 per count) and awarding an additional P100,000.00 as moral damages.