G.R. No. 141186; November 27, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. RAUL S. PULANCO, appellant.

FACTS

The prosecution alleged that on March 11, 1998, inside Camp Capinpin, Tanay, Rizal, appellant Raul Pulanco accosted 14-year-old Ma. Cecilia Gahol and her young niece while they were walking home. Appellant coiled his arm around Cecilia’s neck, poked a knife at her side, and threatened to kill her if she resisted. He dragged her to his nearby hut, pushed her niece away, and forced Cecilia inside. There, he ordered her to undress, threatened her with the knife, and proceeded to have carnal knowledge of her against her will and despite her pleas and physical resistance. After the act, Cecilia went home and immediately reported the rape to her brother, leading to appellant’s arrest that same night. A medico-legal examination revealed findings compatible with recent sexual intercourse.
The defense, solely through appellant’s testimony, claimed that he and Cecilia were sweethearts and that the sexual intercourse on that evening was consensual. He denied using force or intimidation and asserted that the complaint was fabricated. The trial court convicted appellant of rape and sentenced him to reclusion perpetua, prompting this appeal.

ISSUE

Whether the trial court erred in convicting appellant of rape based on the credibility of the complainant’s testimony and in rejecting the appellant’s defense of a consensual relationship.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of Cecilia’s credibility, noting her candid, straightforward, and consistent narration of the harrowing incident, which bore the hallmarks of truth. Her testimony detailed the force, intimidation, and threat with a knife employed by the appellant, satisfying the elements of rape. The medico-legal findings corroborated her claim of recent sexual intercourse. The Court emphasized that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction.
The appellant’s uncorroborated “sweetheart defense” was correctly rejected for being a bare denial, unsupported by any evidence to prove an amorous relationship. Denial cannot prevail over the positive and credible identification by the victim. The Court modified the damages awarded, affirming the ₱50,000 civil indemnity and additionally awarding ₱50,000 as moral damages, which are automatically granted in rape cases without need for further proof, given the inherent trauma suffered by the victim.