GR 172607; (October, 2007) (Digest)
G.R. No. 172607; October 26, 2007
PEOPLE OF THE PHILIPPINES, Appellee, vs. RUFINO UMANITO, Appellant.
FACTS
On July 15, 1989, private complainant AAA was accosted by appellant Rufino Umanito while on her way to her grandmother’s house. Appellant, armed with a fan knife, forced her to a school building where he undressed her and himself, laid her on a bench, and had carnal knowledge of her. He then threatened to kill her if she reported the incident. AAA only disclosed the rape to her mother, BBB, in January 1990 after her mother noticed her protruding stomach. A criminal complaint was filed shortly thereafter. Appellant was arrested in 1995. He pleaded not guilty, denying the accusation and presenting an alibi that he was at home the entire evening. He admitted having courted AAA but claimed she had spurned him.
ISSUE
Whether the prosecution proved appellant’s guilt for the crime of rape beyond reasonable doubt, considering the alleged inconsistencies in AAA’s testimony and the delay in reporting the crime.
RULING
Yes. The Supreme Court affirmed the conviction. The Court held that the alleged inconsistencies in AAA’s testimony—pertaining to minor details such as the exact location where appellant kissed her or who removed her clothes—were trivial and did not detract from the core fact of forcible sexual intercourse. Inconsistencies on minor details can even enhance a witness’s credibility by negating any suspicion of rehearsed testimony. The Court also ruled that the delay in reporting the rape, from July 1989 to January 1990, was sufficiently explained by AAA’s fear due to appellant’s death threats. Such delay is not uncommon for victims of rape, especially when intimidation is involved. The defense of alibi was correctly rejected, as appellant failed to prove it was physically impossible for him to be at the crime scene. His admission of being in the same barrio that evening rendered his alibi weak and unavailing. The trial court’s assessment of AAA’s credible and categorical testimony, corroborated by her subsequent pregnancy, was accorded great weight. Thus, appellant’s guilt was established beyond reasonable doubt.