GR 141782; (December, 2001) (Digest)
G.R. No. 141782; December 14, 2001
PEOPLE OF THE PHILIPPINES, appellee, vs. RENATO FLORES a.k.a. “ATONG,” and PATERNO PARENO a.k.a. “PATTER,” accused, RENATO FLORES a.k.a. “ATONG,” appellant.
FACTS
The prosecution’s version established that on February 2, 1997, in Valenzuela City, the 13-year-old complainant Remedios Renoria was asked by accused Paterno Pareno to accompany him to a nearby nipa hut. Upon arrival, appellant Renato Flores was already present. Pareno dragged her inside, where both men covered her mouth, removed her clothing, and Flores proceeded to have carnal knowledge of her against her will. She reported the incident months later to her uncle, leading to a medico-legal examination which found her hymen intact but distensible, allowing for the possibility of penetration without injury. The defense, however, presented a contradictory narrative. Appellant claimed he and the victim were sweethearts, their marriage was being arranged by their families, and they lived together as a couple for about three months after the alleged incident. He asserted the complaint was filed only after the victim was allegedly coerced by her uncle.
ISSUE
Whether the prosecution proved beyond reasonable doubt the crime of rape through force and intimidation.
RULING
Yes. The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the force or intimidation employed is not gauged by an objective standard of irresistible force but is assessed from the subjective viewpoint of the victim—whether she perceived a real and imminent threat to her life or safety if she did not yield. The victim’s testimony that both accused covered her mouth, preventing any outcry, and forcibly undressed her constituted sufficient intimidation, considering her tender age and the overwhelming physical dominance of two men. The defense of a sweetheart relationship and subsequent cohabitation was rejected. The Court found the victim’s account straightforward and credible, while the appellant’s claim was inherently improbable and unsupported. Denial, being a weak defense, cannot prevail over the victim’s positive and categorical identification. The trial court’s assessment of credibility is accorded great respect. The penalty of reclusion perpetua and civil indemnity were affirmed, with an additional award of moral damages, which is automatically granted in rape cases without need of further proof.