G.R. No. 143658 . April 17, 2002.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMEO PAGURAYAN, JR., accused-appellant.

FACTS

The accused, Romeo Pagurayan, Jr., was charged with the rape of Fe Villote, his housemaid. The Information alleged that on the evening of June 5, 1993, in Banisilan, Cotabato, the accused, using force and intimidation, had carnal knowledge of the victim against her will. The accused pleaded not guilty.
For the prosecution, Fe Villote testified that on the night in question, she was alone in her room when the accused knocked, demanding entry to retrieve something for his firearm. When she refused, he kicked the door open while holding a knife. He pulled her to the bed, covered her mouth, pointed the knife at her neck, removed her clothes, and had sexual intercourse with her despite her resistance and fear. Afterward, she fled to her aunt’s house. The next day, she reported the incident to the police and underwent a medical examination by Dr. Calico Hadji Ali, who found lacerations on her hymen consistent with forcible penetration.
For the defense, the accused denied the rape. He claimed that on the afternoon of June 5, he was drinking beer with his cousin, Aloni Valencia. Upon returning home in the evening, he found Fe Villote sulking about not being sent to school. After he scolded her, she packed her clothes and left the house against his advice to wait for his wife’s return. Aloni Valencia corroborated the accused’s presence with him that night.
The trial court found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua, ordering him to pay indemnity and moral damages.

ISSUE

Whether the trial court erred in giving credence to the testimony of the complainant, Fe Villote, thereby convicting the accused of rape.

RULING

The Supreme Court affirmed the trial court’s decision. The Court found no cogent reason to deviate from the trial court’s assessment of the complainant’s credibility. Fe Villote’s testimony was vivid, credible, and given amidst emotional distress. The Court held that the crime of rape often depends on the victim’s testimony, and the trial court, having observed the witness’s demeanor, is in the best position to assess credibility. The absence of external injuries does not negate rape, and the victim’s reaction of fleeing to her aunt instead of her parents or the police immediately is not unusual, as people react differently to traumatic events. The alleged grudge over not being sent to school was deemed too trivial to motivate a false accusation of rape, which would subject the victim to public humiliation. Therefore, the appealed judgment was affirmed.