GR 174859; (October, 2009) (Digest)
G.R. No. 174859 ; October 30, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JOFER TABLANG, Accused-Appellant.
FACTS
The prosecution charged Jofer Tablang with the rape of AAA, a mentally retarded girl, on March 21, 1997, in Cuyapo, Nueva Ecija. The prosecution presented Dr. Cristina Peñanueva, who testified that her examination of AAA revealed healed hymenal lacerations consistent with sexual intercourse. Francisco Umipig testified that around 11:00 p.m., he found Tablang emerging from a hut on his property, armed with a knife, after which AAA ran out. Dr. Danilo Labay, a psychiatrist, established that AAA suffered from moderate mental retardation with a mental age of 9-12 years. AAA herself testified that Tablang, armed with a knife, removed her clothes, held her hands, and had carnal knowledge with her against her will.
The defense consisted solely of Tablang’s testimony. He claimed he was invited to the hut to eat, and upon arrival, Francisco Umipig falsely accused him of raping AAA while holding a bolo. He denied any sexual encounter. The Regional Trial Court found Tablang guilty of rape and sentenced him to reclusion perpetua, a decision affirmed by the Court of Appeals.
ISSUE
Whether the guilt of accused-appellant Jofer Tablang for the crime of rape was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the credibility of the victim’s testimony is paramount in rape cases. AAA’s categorical and consistent narration of the rape, where Tablang used a knife and force, was deemed credible and sufficient to establish the elements of the crime. Her mental condition did not impair her ability to give a credible account; rather, it bolstered the unlikelihood of fabrication. The medical findings of healed hymenal lacerations corroborated her claim of penetration.
The Court rejected Tablang’s defense of denial and frame-up, which could not prevail over the positive identification and credible testimony of the victim. The alleged ill motive of the witness, Francisco Umipig, was insufficient to overturn the consistent evidence of the prosecution. The presence of a weapon established the intimidation necessary for rape. The Court also ruled that the proper penalty was reclusion perpetua, as the crime was committed before the effectivity of the Death Penalty Law ( R.A. No. 7659 ) for rape with a mentally disabled victim. Civil indemnity, moral damages, and exemplary damages were awarded to the victim.