G.R. No. 134526; December 11, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PATRICK A. COLISAO, accused-appellant.

FACTS

On the evening of December 3, 1997, 13-year-old Maylene Tabin was watching television at a neighbor’s house in Asingan, Pangasinan, where the accused-appellant, Patrick Colisao, was also present. Maylene stepped out to relieve herself. As she stood up, Colisao seized her from behind, covered her mouth, and dragged her to a nearby river. There, he removed her shorts and underwear and his own shorts, and succeeded in having carnal knowledge of her against her will and through intimidation, threatening to kill her if she shouted. Maylene’s father, Melecio, became alarmed when his other children returned home without her and a witness reported seeing Colisao pulling Maylene toward the river. After a frantic search, he found Maylene at home in a state of shock, and she reported the rape. A medical examination confirmed the loss of her physical virginity, showing fresh hymenal lacerations and bleeding.
The defense presented a starkly contrasting narrative. Colisao denied the rape, claiming he and Maylene were sweethearts whose relationship was limited to innocent affection. He testified that on the night in question, he went to collect a debt from Maylene’s father, later met Maylene at the store, and they watched TV elsewhere. He alleged that Maylene later proposed they elope, but she changed her mind upon hearing her father call for her. He asserted that the accusation was fabricated, possibly due to the unpaid debt or as a pretext to force him into marriage.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Patrick Colisao committed the crime of rape against Maylene Tabin.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s testimony is paramount in rape cases. Maylene’s categorical, consistent, and straightforward account of the violent assault was found credible and sufficient to establish the crime. Her testimony was corroborated by the physical evidence of fresh hymenal lacerations and the prompt report to her father and authorities. The Court found the defense of a sweetheart relationship and proposed elopement to be inherently improbable and a mere fabrication to escape liability. It noted the significant age and physical disparity between the 25-year-old, married appellant and the 13-year-old victim, which bolstered the finding of force and intimidation. The claim of a motive to fabricate due to a debt was deemed insufficient to overturn the positive identification and credible testimony of the victim. Consequently, the trial court’s judgment was affirmed with modification, ordering the appellant to pay additional civil indemnity and actual damages.