G.R. No. 206267, March 25, 2015
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RONNIE BUAT alias DATU SINSUAT, Accused-Appellant.

FACTS

The accused-appellant, Ronnie Buat alias Datu Sinsuat, was charged with the rape of AAA. On June 30, 1996, at around 2:00 a.m. in Pagadian City, AAA was sleeping in the sala of her family’s house alongside her married sister DDD, DDD’s husband (the appellant), and her twin nephews. AAA’s mother was away, and her father was on night duty. AAA was awakened by the appellant, who was half-naked and lying on top of her. He covered her mouth with his right hand, removed her panties with his left hand while holding a knife, and threatened to kill her if she told anyone. He inserted two fingers and then his penis into her vagina. After raping AAA, the appellant proceeded to have intercourse with his wife DDD. AAA told DDD about the rape, but DDD ignored her. AAA later reported the incident to her brother and, upon his return, her father CCC. The incident was blottered at the police station on July 3, 1996. AAA was medically examined on July 8, 1996, and the findings showed healed hymenal lacerations. The appellant denied the rape, claiming that AAA was the one who initiated inappropriate contact, which he parried, leading his wife to scold AAA. He asserted that his in-laws were opposed to his marriage. The Regional Trial Court found him guilty of rape and sentenced him to reclusion perpetua, ordering him to pay indemnity and moral damages. The Court of Appeals affirmed the decision. The appellant appealed to the Supreme Court, arguing improbabilities and inconsistencies in AAA’s testimony.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the appellant’s conviction. The Court held that the prosecution successfully established the appellant’s guilt beyond reasonable doubt. The testimony of AAA was found to be credible, straightforward, and consistent on the material points of the rape. The Court addressed the appellant’s arguments: 1) The sequence of acts (covering the mouth, holding a knife, removing panties, and inserting fingers) was physically possible as they were done successively, not simultaneously. 2) The inconsistency between AAA’s testimony (appellant covered her mouth with his right hand) and her sworn statement (left hand) pertained to a trivial detail that did not affect the core fact of rape. 3) Whether the appellant also had intercourse with his wife was immaterial to the charge of raping AAA. 4) The lack of vigorous physical resistance was justified due to the threat and intimidation caused by the knife. 5) The timing of when AAA informed DDD was clarified during cross-examination and did not constitute a material inconsistency. The Court modified the damages awarded, increasing the civil indemnity and moral damages to ₱50,000.00 each and awarding ₱30,000.00 as exemplary damages, all with interest at 6% per annum from the finality of the decision until fully paid. The penalty of reclusion perpetua was affirmed.