GR 146020; (May, 2002) (Digest)
G.R. No. 146020 ; May 29, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NORMAN PALARCA y MERCADO alias “Bong”, accused-appellant.
FACTS
The prosecution alleged that on May 19, 1998, at 5:00 a.m., accused-appellant Norman Palarca raped 70-year-old widow Concepcion Javier in her home in Bulacan. Javier, who had taken a sleeping pill, was tending her sari-sari store when Palarca, a frequent customer, entered through her kitchen door. He assaulted her, punching her abdomen, forcing her to the ground, and then proceeded to have carnal knowledge against her will. Javier reported the rape to her daughter and subsequently underwent a medico-legal examination which documented multiple abrasions in her vaginal canal and contusions on her body, corroborating her account of a violent assault.
The defense presented an alibi, claiming Palarca attended a party and was at Javier’s store only until 3:00 a.m. to buy beer before going home. The trial court convicted Palarca of rape under Article 266-A of the Revised Penal Code and sentenced him to reclusion perpetua, ordering him to pay P50,000.00 in moral damages. Palarca appealed, challenging the credibility of the complainant, the improbability of the events, and the integrity of the physical evidence.
ISSUE
The core issue is whether the prosecution evidence established the guilt of the accused-appellant for the crime of rape beyond a reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court held that the trial court’s assessment of witness credibility is accorded great weight, as it is in the best position to observe demeanor. The detailed and consistent testimony of the private complainant, a 70-year-old woman, was found credible and sufficient to establish the elements of rape through force. Her advanced age made her account inherently trustworthy, and her immediate report to her daughter bolstered her credibility.
The medico-legal report, which showed multiple vaginal abrasions and bodily contusions, provided strong physical corroboration of a violent sexual assault and supported her narrative of resistance. The defense of alibi was rightly rejected for being weak and unsubstantiated, especially against the positive identification by the victim. The Court modified the damages, awarding an additional P50,000.00 as civil indemnity, which is mandatory upon a finding of rape, distinct from the moral damages already awarded. The penalty of reclusion perpetua was affirmed.