GR 134633; (April, 2004) (Digest)
G.R. No. 134633; April 14, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. ALVIN CAPARAS, appellant.
FACTS
On August 5, 1997, appellant Alvin Caparas convinced complainant Marilou Lumabas to accompany him to fetch her drunk husband. While walking, Caparas suddenly pulled her down, choked her, punched her stomach, and threatened to kill her if she screamed, causing her to lose consciousness. She awoke two hours later, naked from the waist down. She crawled for help to a neighbor’s house, where barangay tanods found her. She immediately identified “Alvin” as her assailant. Her clothing was later recovered from the scene.
The medical examination confirmed multiple abrasions and contusions on her face, neck, shoulders, and torso, consistent with strangulation and physical struggle. The medico-legal officer concluded the injuries supported her account of resistance. The examination also found her in a non-virgin state but negative for spermatozoa. The defense consisted of denial and alibi, claiming Caparas was at home using the toilet during the alleged incident.
ISSUE
Whether the prosecution proved beyond reasonable doubt that appellant Alvin Caparas is guilty of rape.
RULING
Yes, the Supreme Court affirmed the conviction. The Court emphasized that the credibility of the complainant, who testified in a clear and categorical manner, was paramount. Her prompt reporting of the crime and consistent identification of the appellant right after regaining consciousness lent credibility to her testimony. The medical findings, particularly the injuries on her neck and body, corroborated her narrative of a violent struggle and use of force. The Court explicitly ruled that the absence of spermatozoa or fresh vaginal lacerations does not negate rape, as these are not elements of the crime. Force and intimidation were sufficiently established through the appellant’s acts of choking, punching, and issuing death threats, which rendered the complainant unconscious and incapable of giving consent. The defense of denial, being inherently weak and self-serving, could not overcome the positive and credible testimony of the victim, who had no motive to falsely accuse the appellant and subject herself to the ordeal of a public trial. The decision of the Regional Trial Court was affirmed with the modification of awarding civil indemnity of ₱50,000 in addition to moral damages.