G.R. No. 175782 ; August 24, 2007
THE PEOPLE OF THE PHILIPPINES, vs. DOMINGO HAPIN y JAZO, Appellant.

FACTS

On April 13, 2002, AAA, a sales supervisor, accepted a ride home from appellant Domingo Hapin, a tricycle driver who was a neighbor and distant relative. During the trip, a heavy downpour occurred. 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 backseat, and succeeded in having carnal knowledge against her will. After the act, he assisted her in dressing and took her home. AAA immediately reported the rape to her parents, who noted her disheveled and distressed state. 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 date was consensual. He asserted that AAA filed the case 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 found him guilty 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 Court of Appeals erred in affirming appellant’s conviction for rape, specifically in upholding the credibility of the victim’s testimony over the defense of a consensual relationship.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s account was found to be clear, consistent, and candid, detailing the use of a bladed weapon, the force employed, and her immediate outcry to her parents and authorities. Her straightforward narration, coupled with the medico-legal findings of physical trauma and the presence of spermatozoa, constituted strong evidence of forcible intercourse. The defense of a consensual relationship was rejected as a mere fabrication. The Court ruled that such a defense, common in rape cases, cannot prevail over the positive and credible testimony of the victim, especially when her actions following the incident—immediate reporting and medical examination—were consistent with that of a violated woman. The award of damages was sustained, with the Court noting that the trial court’s assessment of witness credibility is entitled to great respect.