GR 140235; (May, 2002) (Digest)
G.R. No. 140235 & 142748; May 9, 2002
PEOPLE OF THE PHILIPPINES, appellee, vs. PEDRO DARAMAY JR., appellant.
FACTS
Appellant Pedro Daramay Jr. was charged with two counts of rape allegedly committed on January 14 and 31, 1998, against Diana Estadilla. The prosecution’s evidence established that on January 14, 1998, while Diana was on an errand, Daramay, her neighbor, called her to his house. Upon approach, he suddenly dragged her inside, covered her mouth, pinned her against a wall, and forcibly had carnal knowledge with her despite her resistance. He then threatened her to prevent disclosure. Diana executed a sworn statement on March 11, 1998, leading to Daramay’s arrest and trial.
The defense consisted of a denial that the January 14 incident occurred. Daramay claimed his sexual encounter with Diana was consensual on a different occasion. He attempted to impeach her credibility by asserting she visited his house subsequently, including on January 31 to seek cooking instructions from his wife. The Regional Trial Court of Iriga City convicted Daramay for the rape on January 14 (Criminal Case No. Ir-4716) but dismissed the charge for January 31 (Criminal Case No. Ir-4717) for insufficiency of evidence.
ISSUE
Whether the trial court erred in convicting the appellant based on the sufficiency and credibility of the prosecution’s evidence.
RULING
The Supreme Court affirmed the conviction. The ruling emphasized that in rape cases, the sole testimony of the victim, if clear, credible, and consistent, is sufficient to support a conviction. The Court found Diana’s testimony to be positive, straightforward, and worthy of belief, detailing the force, intimidation, and sexual act. Her immediate execution of a sworn statement corroborated her account.
The Court held that the appellant’s bare denial and imputation of consensual sex could not prevail over Diana’s positive identification and categorical narration. Denials are inherently weak evidence and, absent clear proof of ill motive, cannot overcome affirmative testimony. The Court also deferred to the trial court’s superior position in assessing witness credibility, noting no reason to overturn its findings. The award of damages was modified, granting P50,000 as civil indemnity and P25,000 as moral damages, in line with prevailing jurisprudence. The appeal was denied for lack of merit.