GR 175782; (August, 2007) (Digest)
G.R. No. 175782; August 24, 2007
THE PEOPLE OF THE PHILIPPINES, vs. DOMINGO HAPIN y JAZO, Appellant.
FACTS
On April 13, 2002, appellant Domingo Hapin, a tricycle driver, offered a ride home to AAA, a neighbor and distant relative. While en route during a heavy downpour, appellant stopped the tricycle on a highway shoulder, turned off the lights, and falsely claimed an engine defect. He then entered the sidecar, sat on AAA’s knees, produced a bladed weapon, and forcibly kissed her. Despite her struggles, he removed her clothes, made her lie down on the tricycle’s backseat, and succeeded in having carnal knowledge. Afterward, he assisted her in dressing and dropped her at her home gate. AAA immediately reported the rape to her parents, who noted her disheveled state and distress. She was medically examined, with findings of erythema on her breast and genitals and a positive smear for spermatozoa, consistent with forced intercourse.
Appellant denied the charge, claiming he and AAA were lovers and that their sexual encounter on that occasion was consensual. He asserted that AAA filed the complaint to protect her reputation, as their tricycle was parked in a visible area. His siblings corroborated his claim of a romantic relationship. The Regional Trial Court convicted appellant of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction but added an award for exemplary damages.
ISSUE
Whether the prosecution proved appellant’s guilt for the crime of rape beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction, upholding the credibility of AAA’s testimony. The Court emphasized that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction. AAA provided a clear, consistent, and categorical account of the assault, detailing how appellant used a bladed weapon and force to overcome her resistance. Her immediate report to her parents and the police, coupled with her distraught physical condition, bolstered her credibility. The medical findings, showing trauma and the presence of spermatozoa, objectively corroborated her claim of non-consensual intercourse.
The Court rejected appellant’s defense of a romantic relationship as a mere fabrication. It noted that such a claim is a common and weak defense in rape cases. The testimonies of appellant’s siblings were deemed biased and insufficient to overcome the positive identification by the victim. The Court found no ill motive for AAA to falsely accuse a neighbor and relative, thereby exposing herself to public scrutiny. The elements of rape—carnal knowledge through force or intimidation—were established beyond reasonable doubt. The award of civil indemnity, moral damages, and exemplary damages was sustained.