G.R. No. 144053 ; December 11, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. JOSEPH DIZON Y NARIDO, appellant.

FACTS

The appellant, Joseph Dizon, was charged with the rape of Janice May Salvador, a 15-year-old high school graduate. The prosecution’s narrative established that the victim and appellant were connected through a mutual friend. On May 21, 1996, they met for the first time at an LRT station under the pretext of visiting their friend. Appellant persuaded Janice to first accompany him to a hospital to see his mother and then to Pasay City to deliver documents. Instead, they were taken via taxi to an apartelle. Inside a room, appellant brandished a firearm, threatened to kill Janice, and forcibly had sexual intercourse with her despite her resistance and pleas.
The defense presented a different version, claiming the sexual act was consensual. Appellant testified that he and Janice were sweethearts and that they checked into the apartelle for a private encounter. He denied using a gun or issuing threats. The trial court, however, found the prosecution’s evidence credible and convicted appellant of rape, sentencing him to reclusion perpetua and ordering him to pay indemnity.

ISSUE

The core issue is whether the prosecution proved the appellant’s guilt for the crime of rape beyond reasonable doubt, specifically overcoming the defense of consensual sex.

RULING

The Supreme Court affirmed the conviction. The Court meticulously analyzed the credibility of the witnesses and found the testimony of the private complainant to be clear, candid, and consistent on material points. Her detailed account of being deceived, threatened with a gun, and forcibly subdued was deemed credible and constituted the essential elements of rape through force and intimidation. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction.
The defense of a sweetheart relationship was rejected for being unsupported by credible evidence and inherently implausible given the circumstances of their first meeting. The Court noted the unnatural behavior attributed to the complainant by the defense, such as immediately engaging in sexual activity with a virtual stranger. Furthermore, the complainant’s conduct after the incident—immediately reporting the rape to her mother and undergoing a medical examination—was consistent with that of a victim and bolstered her credibility. The trial court’s assessment of witness credibility was accorded great respect. The penalty of reclusion perpetua was affirmed, and the damages awarded were modified in line with prevailing jurisprudence.