GR 148144; (April, 2004) (Digest)
G.R. No. 148144; April 30, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. FLORENCIO CADAMPOG, appellant.
FACTS
On January 14, 1996, in Maramag, Bukidnon, appellant Florencio Cadampog entered the house of Prudencia Lasara while her husband was away. He grabbed her, kissed her, and despite her vigorous resistance, removed her panties and his pants. He then inserted his penis into her vagina and made push-and-pull movements. Prudencia managed to push him away, causing him to ejaculate outside her body. The appellant threatened to kill her if she reported the incident. Prudencia immediately reported the rape to barangay officials and later to the police. A medical examination revealed linear abrasions on her face, neck, and chest, consistent with her account of struggle, though no spermatozoa were found due to the lapse of time.
The appellant denied the accusation, interposing alibi. He claimed he was cutting cogon grass with his wife and daughter the entire day. He alleged the charge was fabricated because he refused to be a witness for Prudencia in a different case. His wife corroborated his alibi and testified that Prudencia demanded ₱80,000 to withdraw the complaint. The trial court convicted the appellant of rape and sentenced him to reclusion perpetua, ordering him to pay damages.
ISSUE
Whether the guilt of the appellant for the crime of rape was proven beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction. The Court found the testimony of the victim, Prudencia Lasara, to be credible, straightforward, and consistent. Her detailed account of the violent assault, her immediate reporting to authorities, and the physical injuries documented by the medico-legal officer strongly corroborated her testimony. The medical finding of no spermatozoa does not negate rape, as its absence is explained by the appellant’s external ejaculation and the delay before the examination. The defense of alibi is inherently weak and cannot prevail over the positive identification by the victim. The claim of a fabricated charge due to a refused request to testify was deemed unconvincing and unsupported by evidence. The Court modified the damages awarded, deleting the unsubstantiated actual damages and awarding civil indemnity, moral damages, and exemplary damages in line with prevailing jurisprudence. The decision of the Regional Trial Court was affirmed with modifications to the awards.