GR 153219; (December, 2003) (Digest)
G.R. No. 153219; December 1, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. EDGAR MOLLEDA y PONTANES @ Medy, appellant.
FACTS
On January 25, 1999, appellant Edgar Molleda arrived at the house of Juana Bernaser Bucad and her common-law husband, Felipe Roma, in Kalayaan, Laguna. Molleda deceitfully told Felipe that an NPA member wanted to speak with him by a distant creek, prompting Felipe to leave. Once alone with Juana, Molleda dragged her to a nearby camote plantation. There, he pointed a gun at her, ordered her to undress, and proceeded to have carnal knowledge of her against her will. After the act, Molleda threatened to kill Juana if she reported the incident.
Juana immediately reported the rape to Felipe upon his return. The following day, she and Felipe went to the police station to file a report, and she underwent a medical examination. The medico-legal report noted old healed lacerations on her hymen. Appellant denied the accusation, presenting an alibi that he was at a friend’s house during the incident.
ISSUE
Whether the trial court erred in convicting appellant of rape based on the credibility of the complainant’s testimony.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim is paramount. The trial court’s assessment of witness credibility is accorded great respect, as it observes the witness’s demeanor firsthand. Juana’s testimony was found to be credible, natural, and consistent. Her immediate disclosure of the incident to her partner, her prompt reporting to authorities, and her submission to a medical examination strongly corroborated her account and were indicative of an honest complaint.
The Court ruled that all elements of rape were present. Carnal knowledge was established through Juana’s positive identification. Intimidation, substituting for force, was sufficiently proven by appellant’s use of a gun and his subsequent death threat, which instilled fear and rendered resistance futile. The absence of fresh physical injuries or spermatozoa does not negate rape, as the crime can be consummated without these. The defense of alibi was weak and could not prevail over the positive identification by the victim. The penalty of reclusion perpetua and the awards of civil indemnity and moral damages were affirmed as proper under prevailing jurisprudence.