G.R. No. 175600 ; April 23, 2008
PEOPLE OF THE PHILIPPINES, appellee, vs. LEONEL PASAOL PALAC alias JOY-JOY TALAC, REY ARGENTILLO AND JOJO VILARDE, accused. LEONEL PASAOL PALAC alias JOY-JOY TALAC, appellant.

FACTS

The appellant, Leonel Palac, along with two others, was charged with three counts of rape committed in conspiracy against AAA, a 15-year-old minor, on May 14, 1996, in Pasay City. The prosecution evidence established that AAA, after being advised by an accused to stay overnight, was given a beverage by him, causing her to feel dizzy. She was led to a photoshop where the three accused were present. While lying on a sofa, she overheard them conspiring to take turns raping her. Despite her desire to resist, she felt paralyzed and helpless. Vilarde and Argentillo successively had carnal knowledge of her, followed by the appellant. Appellant later warned her not to report the incident. The case was filed months later after AAA’s mother learned of the crime. Only appellant was tried as his co-accused remained at-large.
The appellant denied the charges and interposed alibi, claiming he was elsewhere and that he saw AAA drinking with others that night. The Regional Trial Court found him guilty beyond reasonable doubt of three counts of rape and sentenced him to three penalties of reclusion perpetua. The Court of Appeals affirmed the conviction with modifications to the damages awarded. Appellant appealed to the Supreme Court, arguing the trial court erred in giving credence to AAA’s testimony.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for three counts of rape based on the credibility of the victim’s testimony.

RULING

The Supreme Court dismissed the appeal and affirmed the appellant’s conviction. The Court emphasized that the credibility of the rape victim is of paramount importance. AAA’s detailed and consistent narration of the harrowing experience, where she was successively violated by three men, was found to be credible and worthy of belief. The Court noted that minor inconsistencies in her testimony regarding peripheral details, such as the exact time of the assaults, did not undermine her core account of the rape, as they are to be expected from a traumatized victim recounting a painful ordeal. The defense of alibi was rightly rejected for being weak and unsubstantiated, especially as it could not prevail over the positive identification by the victim. The finding of conspiracy was sustained based on the accused’s collective actions—discussing the crime, taking turns, and standing guard—which demonstrated a common criminal purpose. The penalty of reclusion perpetua for each count was affirmed as proper, with the Court also upholding the award of civil indemnity, moral damages, and exemplary damages to the victim.