G.R. No. 176062 ; July 4, 2008
PEOPLE OF THE PHILIPPINES, appellee, vs. EFREN CUSTODIO y ESTEBAN, appellant.

FACTS

The appellant, Efren Custodio, was convicted of three counts of simple rape against his 19-year-old niece, AAA. The incidents occurred on November 5, 6, and 7, 1999, in Plaridel, Bulacan. The prosecution established that appellant, an uncle, lured AAA under the pretense of finding her a job. He brought her to different locations, introduced her as his wife, and took her money to prevent escape. On each of the three nights, at the house of a friend, appellant had carnal knowledge of AAA at knifepoint, threatening to kill her if she reported the assaults. AAA was rescued by her brother on November 8, 1999, after which she immediately reported the rapes and underwent a medico-legal examination, which confirmed her non-virgin state.
The appellant admitted to the sexual intercourse but claimed a “sweetheart theory,” alleging that AAA was his consenting girlfriend and that they had eloped. He asserted that the relationship was consensual and that AAA had given him tokens of affection. The trial court and the Court of Appeals rejected this defense, finding AAA’s testimony credible, straightforward, and consistent. The trial court convicted appellant, and the Court of Appeals affirmed the conviction with modifications to the damages awarded.

ISSUE

The core issue is whether the prosecution proved the appellant’s guilt for three counts of rape beyond reasonable doubt, overcoming his defense of a consensual romantic relationship.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim is paramount in rape cases. AAA’s detailed, candid, and unwavering testimony on how her uncle abused his familial relation, employed deception, and used a deadly weapon to force sexual intercourse upon her was found credible and sufficient to establish guilt. The medical findings, while not showing fresh injuries, corroborated her non-virgin state and were consistent with her narrative. The Court found the appellant’s “sweetheart theory” inherently improbable and a mere fabrication to escape liability. It is contrary to human nature and experience for a young woman to fabricate a story of multiple rapes by her own uncle, subjecting herself to public scrutiny and the ordeal of a trial, if it were not true. The defense failed to show any ill motive for AAA to falsely accuse him. The element of carnal knowledge through force or intimidation was thus conclusively proven. The Court also held that any alleged defect in the Informations for stating “with lewd designs” instead of specifying force and intimidation was waived by the appellant’s failure to quash them before arraignment, and he was in fact fully apprised of the nature of the accusations against him.