G.R. No. 168448; October 8, 2008
People of the Philippines, plaintiff-appellee, vs. Fajardo Napudo, accused-appellant.

FACTS

Accused-appellant Fajardo Napudo was charged with rape under Article 266-A of the Revised Penal Code, as amended, in relation to Republic Act Nos. 7659 and 7610. He pleaded not guilty, claiming at pre-trial that his sexual intercourse with AAA was voluntary and consensual as they were sweethearts. The prosecution presented AAA, her mother BBB, and Dr. Elizabeth Joaquin. AAA testified that on December 3, 1998, while walking home from a jeepney ride, Napudo, her cousin, forcibly dragged her to a clump of bamboos, pushed her to the ground, and after she lost consciousness, raped her under a “camarin.” He threatened to kill her if she reported it. AAA later exhibited trauma, stopped eating and sleeping, and ultimately committed suicide eighteen days after her court testimony. Medical examination revealed a hymenal laceration and vaginal abrasion consistent with recent penetration. The defense presented Napudo and witnesses to support his “sweetheart” defense, alleging consensual sexual encounters, including at a hotel. The RTC found Napudo guilty of rape and sentenced him to reclusion perpetua, ordering him to pay moral damages and civil indemnity. The CA affirmed with modification.

ISSUE

Whether the Court of Appeals gravely erred in convicting accused-appellant of rape based on reasonable doubt and in ignoring his claim of a consensual affair.

RULING

The Supreme Court denied the appeal and affirmed the CA decision. The Court held that the prosecution proved Napudo’s guilt beyond reasonable doubt. AAA’s detailed, candid, and consistent testimony, corroborated by medical findings, established the rape. Her subsequent suicide strongly evidenced the trauma and supported her lack of consent. The Court rejected the “sweetheart” defense as inherently weak and unsupported by credible evidence; the defense witnesses’ testimonies were unreliable, and the hotel logbook was dubious. The Court ruled that even if a relationship existed, it does not negate rape when force or intimidation is proven. The absence of external injuries does not disprove rape, as resistance is not required when the victim is overcome by fear or rendered unconscious. The award of damages was modified, increasing civil indemnity and moral damages and awarding exemplary damages.