G.R. No. 135242; April 19, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RICARDO BAYLEN, accused-appellant.

FACTS

The accused-appellant, Ricardo Baylen, was charged with the rape of Rosalyn Centeñales on March 18, 1995, in Calinog, Iloilo. The prosecution alleged that Baylen, armed with a knife and appearing drunk, accosted the 17-year-old complainant while she was fetching water. He poked the knife at her chest, pulled her downhill, and despite her resistance, succeeded in having carnal knowledge of her twice, threatening to kill her and her family if she reported the incident. Frightened, Centeñales did not go home that night. The following day, she reported the rape to the barangay captain and the police.
Medical examinations conducted days after the incident revealed no fresh lacerations or hematoma on the victim, but the doctors testified that the absence of such physical injuries does not negate the possibility of sexual intercourse, especially given the time lapse. During a barangay assembly, Baylen reportedly offered to support a child if the complainant gave birth to a boy. In his defense, Baylen presented an alibi, claiming he was at a fiesta in a neighboring barangay during the alleged incident, and was corroborated by several witnesses. The Regional Trial Court convicted Baylen of rape and sentenced him to reclusion perpetua.

ISSUE

Whether the guilt of the accused-appellant for the crime of rape was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the complainant’s testimony, which was candid, consistent, and straightforward, prevails over the accused’s denial and alibi. The medical findings, while not showing fresh injuries, were adequately explained by expert testimony stating that intercourse is possible without leaving detectable physical traces, especially after several days. The Court ruled that force and intimidation were sufficiently established by the complainant’s detailed account of being threatened with a knife, which instilled a reasonable fear for her life and that of her family, compelling her submission. The absence of external physical injuries does not disprove rape, as intimidation can subdue a victim without a struggle.
The use of a deadly weapon qualified the crime, warranting the penalty of reclusion perpetua to death. With no modifying circumstances, the lesser penalty of reclusion perpetua was correctly imposed. The Court modified the damages, awarding an additional P50,000 as civil indemnity ex delicto, in line with prevailing jurisprudence, to the previously awarded P50,000 moral damages. The appeal was denied.