GR 174370; (July, 2009) (Digest)
G.R. No. 174370 ; July 23, 2009
PEOPLE OF THE PHILIPPINES, Appellee, vs. WILLY MARDO GANOY y MAMAYABAY, Appellant.
FACTS
The prosecution’s evidence established that on March 28, 2002, AAA, a 17-year-old waitress, was on her way home from work in Valenzuela City. Appellant, who had previously made advances towards her, boarded the same tricycle. After discovering AAA’s brother was not home, they proceeded to another location. In a dimly lit area, appellant suddenly grabbed AAA, dragged her to a vacant lot, and twisted her arms when she resisted. He then poked a knife at her side, threatened her, and forcibly had sexual intercourse with her. After the act, he detained her in a deserted bodega until daybreak. AAA immediately reported the rape to the police, who arrested appellant. A medico-legal examination revealed abrasions on AAA and the presence of spermatozoa, corroborating recent sexual intercourse.
The defense presented a contrary version. Appellant claimed he and AAA were longtime sweethearts and that she had followed him to his warehouse to apologize for a quarrel and to ask for money for a prior abortion. Defense witnesses testified they saw AAA voluntarily enter the compound and heard her asking appellant for money. Appellant denied the rape allegation, asserting the sexual act was consensual and that AAA filed the case because he refused to give her money.
ISSUE
Whether the prosecution proved beyond reasonable doubt that appellant is guilty of the crime of rape.
RULING
Yes. The Supreme Court affirmed appellant’s conviction for rape. The Court emphasized that the credibility of the complainant is paramount in rape cases. AAA gave a clear, consistent, and candid account of the forcible sexual assault, including the use of a knife and threats, which was not impaired by any ill motive. Her immediate reporting of the crime to the police bolsters her credibility. The medico-legal findings of physical injury (an abrasion) and the presence of spermatozoa provided strong physical corroboration of her testimony.
The Court found the defense of a sweetheart relationship unconvincing and unsupported by credible evidence. Appellant failed to present any tangible proof, such as love notes or mementos, to substantiate this claim. The testimonies of defense witnesses were deemed insufficient to overthrow the positive identification and detailed narration of the victim. The alleged motive of extortion was not proven. The trial court’s assessment of witness credibility is accorded great respect, as it is in the best position to observe demeanor. Thus, the prosecution successfully discharged its burden of proving appellant’s guilt beyond reasonable doubt.