G.R. No. 179570 ; February 4, 2010
EGAP MADSALI, SAJIRON LAJIM and MARON LAJIM, Petitioners, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioners Sajiron Lajim and Maron Lajim were charged with abduction with rape (Criminal Case No. 12281). Petitioners Egap Madsali and Sajiron Lajim were charged with serious illegal detention (Criminal Case No. 12309). The cases were consolidated. The prosecution evidence established that on July 1, 1994, Sajiron, armed with a bolo, forcibly took AAA, a 15-year-old, while she was fetching water. He threatened to kill her and her aunt. Maron, Sajiron’s father, appeared with a gun and assisted. They tied AAA, brought her to a forest, where Sajiron raped her three times while Maron stood guard. The next day, they brought AAA to Egap Madsali’s house, where she was detained. Egap was instructed to guard AAA and threaten to kill her if she escaped. AAA’s mother attempted to retrieve her but was threatened by Egap. Nine days later, AAA was forced to marry Sajiron in a ceremony solemnized by an Imam. AAA was detained from July 2 to December 15, 1994, during which Sajiron continued to sexually abuse her, resulting in pregnancy. The defense claimed AAA and Sajiron were engaged for three years, eloped, and married voluntarily, and that the case was filed due to non-payment of dowry. The RTC found the petitioners guilty. The CA affirmed the RTC decision.

ISSUE

1. Whether the five-month delay by AAA’s mother in reporting the abduction and detention affects the credibility of the charges.
2. Whether the unrebutted testimony of AAA’s father casts reasonable doubt on the charges.

RULING

The Supreme Court denied the petition and affirmed the CA decision.
1. The delay in reporting was sufficiently explained and does not affect credibility. AAA’s mother testified that she did not immediately report the incident because Egap Madsali threatened to kill AAA if she did. Furthermore, when Egap learned she had reported it, he shot her. Delay due to threats is reasonable and does not render the charge doubtful.
2. The testimony of AAA’s father does not cast reasonable doubt. The trial court’s assessment of witness credibility is accorded great respect, as it had the opportunity to observe their demeanor. The positive and categorical testimony of AAA, detailing the abduction, rape, and detention, prevails over the denial and allegations of the defense. The claim of a prior courtship and voluntary marriage is belied by the evidence of force, threats, and the circumstances of the detention.