GR 148368; (July, 2003) (Digest)
G.R. Nos. 148368-70; July 8, 2003
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO FABIAN Y MARI, accused-appellant.
FACTS
Accused-appellant Eduardo Fabian was charged with three counts of rape. The victim, Marietta Tingson, a 51-year-old widow, rented a room in the house of appellant’s mother, where appellant also resided. She testified that on three separate occasions—August 16, 1998, October 3, 1998, and March 15, 1999—the appellant sexually assaulted her through force, intimidation, and threats against her and her mentally retarded son. She described each incident in detail, including her resistance and the appellant’s use of physical violence to subdue her. Despite immediate threats not to report the incidents, she eventually disclosed them to barangay authorities and the police in May 1999.
The defense interposed denial and alibi, claiming the charges were fabricated due to a dispute over unpaid rent. The Regional Trial Court convicted Fabian of three counts of rape and sentenced him to reclusion perpetua for each count. The case was elevated to the Supreme Court on automatic review.
ISSUE
Whether the prosecution proved the guilt of the accused-appellant for three counts of rape beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court meticulously reviewed the victim’s testimony and found it credible, consistent, and sufficient to establish all elements of rape under Article 266-A of the Revised Penal Code, as amended by R.A. 8353. The Court emphasized that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction. Marietta’s detailed narration of the force, intimidation, and carnal knowledge was corroborated by her prompt reporting to friends and family shortly after each incident, and her eventual formal complaint. Her initial reluctance to report was reasonably explained by her fear and the respect she held for the appellant’s family.
The Court rejected the defense of denial and alibi for being inherently weak and unsubstantiated by clear and convincing evidence. It held that the positive identification by the victim prevails over such defenses. The trial court’s assessment of witness credibility was accorded great weight. Accordingly, the penalty of reclusion perpetua for each count was affirmed. The Court also modified the damages, awarding an additional P50,000.00 as moral damages for each count, in line with prevailing jurisprudence.