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, a neighbor, entered the house of Prudencia Lasara while her husband was away. He grabbed her, kissed her, and despite her vigorous resistance, removed her panties. He then inserted his penis into her vagina. 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 in another case Prudencia contemplated filing. His wife corroborated his alibi and testified that Prudencia demanded ₱80,000 to withdraw the case. The trial court convicted the appellant of rape and sentenced him to reclusion perpetua.
ISSUE
Whether the prosecution proved the guilt of the appellant for the crime of rape 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. She provided a detailed account of the sexual assault and her immediate resistance, which was corroborated by the physical injuries documented in the medical certificate. The absence of spermatozoa does not negate rape, as the medical expert explained it could be due to the intervening period before examination. The defense of alibi is inherently weak and cannot prevail over the positive identification by the victim. The claim of a financial motive for the accusation was unsupported by convincing evidence. The Court modified the damages awarded, ordering the appellant to pay ₱50,000 as civil indemnity, ₱50,000 as moral damages, and ₱25,000 as exemplary damages, while deleting the unsubstantiated award for actual damages.