G.R. No. 187075; July 5, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ROMMEL BELO y DE LEON, Accused-Appellant.

FACTS

The prosecution’s evidence established that on November 12, 1999, in Sta. Rosa, Laguna, the victim AAA was taking a bath alone in her house when she noticed the living room lights were off. Upon opening the bathroom door, she was confronted by accused-appellant Rommel Belo, who was holding a bread knife. He pushed her back inside, uttered “sandali lang ito,” and, while pointing the knife at her, proceeded to kiss her, touch her private parts, and ultimately have carnal knowledge of her against her will. He then threatened to kill her if she reported the incident. AAA nevertheless reported the rape to her live-in partner and the authorities. A medical examination confirmed findings consistent with sexual intercourse, including deep, healed hymenal lacerations.
The defense presented a contrary version, alleging a consensual romantic relationship between AAA and the accused-appellant. He claimed AAA had invited him to her house and that their sexual encounter in the bathroom was mutual. He asserted he had even asked friends to follow him to the house to witness their relationship. He alleged AAA only filed charges after they were allegedly seen by these friends.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that accused-appellant committed rape through force, violence, and intimidation with the use of a deadly weapon.

RULING

The Supreme Court affirmed the conviction for rape but modified the penalty. The Court upheld the trial court and the Court of Appeals in giving full credence to the straightforward, candid, and consistent testimony of the victim. Her immediate reporting of the crime to her partner and the police, coupled with the medical findings, lent strong corroboration to her account. The Court found the defense of a secret romantic relationship to be inherently weak and unsubstantiated. The claim that friends were invited to witness the act was deemed illogical and contrary to human experience if the relationship was indeed secret. The presence of the bread knife constituted the requisite force and intimidation, rendering resistance futile and dangerous.
However, the Court modified the penalty. The crime was committed in 1999, prior to the effectivity of the Death Penalty Law (R.A. 9346). Applying the law in force at the time of commission (R.A. 7659), the prescribed penalty for rape with the use of a deadly weapon is reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the lesser penalty of reclusion perpetua was correctly applied. The Court further imposed reclusion perpetua without eligibility for parole, pursuant to prevailing jurisprudence. The award of damages was also modified, increasing the civil indemnity and moral damages to PhP 50,000 each and awarding PhP 30,000 as exemplary damages.