G.R. No. 191265 ; September 14, 2011
People of the Philippines, Plaintiff-Appellee, vs. Marcelo Perez, Defendant-Appellant.

FACTS

The accused-appellant, Marcelo Perez, was charged with the rape of his sister-in-law, AAA, a 16-year-old, on or about June 30, 1998, at around 4:00 a.m. in Albay. The Information alleged he used force, threat, and intimidation. Upon arraignment, he pleaded not guilty. The prosecution presented AAA, her mother BBB, and medico-legal officer Dr. Tirzo de los Reyes, Jr. AAA testified that appellant dragged her from her sleep to the bathroom, covered her mouth with cloth, placed his brief in her mouth, undressed her, forced her down, and inserted his penis into her vagina while threatening her with a knife. She stated she did not resist due to the threat and lost consciousness after appellant slashed her wrist. BBB testified she was informed of the rape while in Manila and later saw AAA’s wrist wound and the brief. Dr. de los Reyes examined AAA two days post-incident and found her vaginal canal admitted two fingers, no hymen was seen, and there were no lacerations or abnormalities noted. The defense rested without presenting any evidence. The Regional Trial Court found appellant guilty beyond reasonable doubt of rape and sentenced him to reclusion perpetua, ordering him to pay civil indemnity and moral damages. The Court of Appeals affirmed the decision in toto. Appellant appealed, attacking AAA’s credibility by pointing to alleged incredulities and inconsistencies in her testimony and the medico-legal findings. The Office of the Solicitor General countered that the failure to shout did not negate rape, inconsistencies were inconsequential, and medical findings were not indispensable.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of appellant Marcelo Perez for the crime of rape based on the credibility of the victim’s testimony and the sufficiency of the evidence presented.

RULING

The Supreme Court affirmed the conviction. The Court held that the prosecution established all elements of rape under Article 266-A of the Revised Penal Code through the credible, straightforward, and unequivocal testimony of the victim, AAA. The elements are: (1) the accused had carnal knowledge of the victim; and (2) the act was accomplished through force or intimidation. AAA’s testimony detailed how appellant, through threat of killing her with a knife, forced carnal knowledge upon her. The Court emphasized that in rape cases, the victim’s credibility is paramount, and when a woman says she was raped, she says all that is necessary to show the crime was committed. The trial court’s assessment of witness credibility is accorded great respect. The alleged inconsistencies (e.g., regarding who was in the house, failure to shout, mechanics of undressing while holding a knife) were deemed minor and did not affect AAA’s core testimony. The absence of fresh lacerations or trauma in the medico-legal report does not negate rape, as such findings are not indispensable for conviction. Appellant’s flight was also considered an indication of guilt. Therefore, the guilt of appellant was proven beyond reasonable doubt.