G.R. No. 171314 March 6, 2007
People of the Philippines, Plaintiff-Appellee, vs. Paterno Oliquino, Accused-Appellant.

FACTS

The prosecution’s evidence established that on September 30, 1995, in Camalig, Albay, the accused-appellant Paterno Oliquino, a stepbrother of the victim AAA’s grandmother, entered the house where AAA was alone. He held her hands, pushed her to the floor, straddled her, and removed her clothing. He then threatened her with a fan knife and proceeded to have carnal knowledge of her against her will. AAA did not immediately report the incident. Her grandmother later noticed her pregnancy, and AAA eventually identified Oliquino as the perpetrator. A medical certificate confirmed her eight-month pregnancy, and she gave birth on June 20, 1996.
The defense presented a theory of a consensual romantic relationship. Oliquino claimed he and AAA were lovers who had engaged in sexual intercourse more than fifty times, starting in June 1995 when she borrowed money from him. He denied the rape, suggesting the kitchen location was implausible due to unsanitary conditions. Defense witnesses testified to seeing the two together intimately, supporting the claim of a consensual affair.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Oliquino committed rape through force, threat, and intimidation, or if the defense successfully established the existence of a consensual sexual relationship.

RULING

The Supreme Court affirmed the conviction. The Court found AAA’s testimony credible, straightforward, and consistent. She provided a detailed account of the rape, including the use of a knife and threats to kill her if she shouted. The Court emphasized that testimonies of rape victims, especially minors, are accorded full credence when they are consistent and natural. The delay in reporting was sufficiently explained by the accused’s threats and the victim’s fear, which is not uncommon, especially given the familial context and the accused’s intimidating presence in the community.
The defense of a love affair was rejected. The Court found the claim of over fifty sexual encounters to be exaggerated and unsupported by credible evidence. The testimonies of defense witnesses were deemed insufficient to overthrow the positive and categorical identification by the victim. The birth of a child, while proof of sexual intercourse, does not negate rape. The medical evidence corroborated the victim’s account regarding her pregnancy timeline. The Court upheld the finding that carnal knowledge was achieved through force and intimidation, thereby constituting the crime of rape. The penalty of reclusion perpetua was affirmed.