G.R. No. 202976, February 19, 2014
People of the Philippines, Plaintiff-Appellee, vs. Mervin Gahi, Accused-Appellant.

FACTS

The accused-appellant, Mervin Gahi, was convicted by the Regional Trial Court of two counts of rape against AAA, his wife’s niece. The incidents occurred on March 11 and 12, 2002, in Capoocan, Leyte. In the first incident, AAA was alone in her grandmother’s house when Gahi arrived, poked a knife at her, pushed her to the floor, and forcibly had carnal knowledge of her. The following day, Gahi again accosted AAA, followed her to the same house, and raped her a second time at knifepoint. AAA, then 16 years old, did not immediately report the rapes out of fear for her life and only disclosed her ordeal months later to her employer after realizing she was pregnant.
At trial, AAA provided a consistent and categorical account of the sexual assaults. The defense presented AAA’s grandmother, BBB, who testified that AAA never reported the incidents to her and that she did not believe the accusations, suggesting AAA had a boyfriend. The trial court and the Court of Appeals found AAA’s testimony credible and convicted Gahi, imposing the penalty of reclusion perpetua for each count.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for two counts of rape beyond reasonable doubt, particularly in light of the defense’s challenge to the victim’s credibility and the alleged delay in reporting the crimes.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s detailed, consistent, and straightforward narration of the two successive rapes, including the use of a deadly weapon, carried the hallmark of truth. The Court found her fear of the accused, who was a relative and armed with a knife, to be a sufficient and reasonable explanation for her initial silence and failure to immediately report the assaults. Delay in reporting, by itself, does not undermine credibility when the delay is satisfactorily explained, as it was here by the threats to her life.
The defense of denial and imputation of ill motive, unsupported by clear and convincing evidence, cannot prevail over the positive and credible testimony of the victim. The medical certificate confirming AAA’s pregnancy, while not conclusive of rape, was consistent with her testimony. The qualifying circumstance of the use of a deadly weapon was duly proven, warranting the penalty of reclusion perpetua for each count. The Court upheld the findings of the lower courts, ruling that no facts or substantial issues were presented to warrant a reversal of the judgment.