GR 187084; (October, 2009) (Digest)
G.R. No. 187084 ; October 12, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CARLITO PABOL, Accused-Appellant.
FACTS
The prosecution established that on October 9, 1997, the 14-year-old victim, AAA, was on her way to school when she encountered her neighbor, accused-appellant Carlito Pabol. After a brief exchange, Pabol suddenly struck her face, causing her to fall. He then hugged her from behind, struck her breast with a stone, and covered her mouth when she shouted. AAA lost consciousness and awoke approximately two hours later alone by the roadside, with her blouse opened, blood on her panty, and multiple lacerations on her face and ears. She reported the incident to her sister, BBB, who noticed bloodstains on AAA’s panty the same afternoon. Medical examination confirmed AAA’s physical injuries and revealed a completely healed hymenal laceration.
The defense presented a partial denial. Pabol admitted to slapping and boxing AAA after she became angry when questioned about her father’s whereabouts. He further admitted to dragging the unconscious AAA to the roadside and fleeing, fearing he had killed her. However, he categorically denied having carnal knowledge of the victim.
ISSUE
Whether the prosecution proved beyond reasonable doubt that Carlito Pabol committed the crime of rape.
RULING
Yes. The Supreme Court affirmed the conviction. The Court emphasized that the victim’s credible and categorical testimony is sufficient to establish the fact of rape. AAA’s detailed account of the initial attack, her loss of consciousness, and her physical state upon regaining consciousness, corroborated by the medical findings of injuries and a healed hymenal laceration, constituted proof beyond reasonable doubt. The Court applied the doctrine that when a victim is rendered unconscious by the violence employed by the accused, sexual intercourse is presumed to have been effected without consent. The defense of denial cannot prevail over the positive and credible testimony of the victim, especially where no ill motive was shown for her to falsely accuse the appellant. The award of civil indemnity and moral damages was sustained, and exemplary damages were additionally awarded. The Decision of the Court of Appeals was affirmed with modification.