G.R. No. 138876 . November 24, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EGMEDIO LAMPAZA, accused-appellant.

FACTS

The accused-appellant, Egmedio Lampaza, was charged with the rape of Teodora Wacay on March 20, 1988, in Tobias Fornier, Antique. The prosecution’s version, as adopted by the trial court, established that on the said date, the victim was at her farm lot. The accused suddenly came from behind, twisted her arms, lifted her, and brought her to an uninhabited nipa hut despite her struggles, kicks, and shouts. Inside the hut, he pinned her down with his knees, placed a bolo beside her, and raped her. The victim’s nephew later found her running from the hut, sobbing, pale, trembling, and afraid. She reported the incident to her husband and mother that evening, and a formal complaint was filed with the police the following day. The defense, however, claimed that the accused and the victim were sweethearts and that the sexual intercourse was consensual. They asserted that the victim signaled to the accused on the day in question, knowing her husband was away, and that they had previously had intimate relations. The defense presented the accused’s wife, who testified that the victim was her husband’s mistress, and her employer, who corroborated that the wife had confided about the marital troubles caused by this relationship.

ISSUE

Whether the accused-appellant is guilty beyond reasonable doubt of the crime of rape.

RULING

Yes, the accused-appellant is guilty beyond reasonable doubt of rape. The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua and increased the moral damages. The Court held that the medical examination of a victim is not a requisite for the successful prosecution of rape; a conviction can be based solely on the credible testimony of the offended party. The Court found the victim’s testimony to be clear, convincing, and consistent, detailing the use of force, intimidation (through the bolo), and lack of consent. The defense of a “sweetheart” relationship was rejected for lack of corroborative proof such as love notes, mementos, pictures, or tokens. The Court emphasized that love is not a license to rape. The testimony of the accused’s wife about the alleged affair was deemed insufficient to prove consent, as it did not directly pertain to the incident and was self-serving. The victim’s conduct after the incident—immediately reporting it and filing a complaint—was consistent with that of a violated woman. The Court also noted that the trial court’s assessment of witness credibility is entitled to great respect.