G.R. No. 215201, December 09, 2015
People of the Philippines, Plaintiff-Appellee, vs. Mark Anthony Roaquin y Navarro, Accused-Appellant.

FACTS

The accused-appellant, Mark Anthony Roaquin, was charged with the rape of AAA, a 17-year-old minor, on October 7, 2007, in Makati City. The prosecution’s evidence established that AAA, while walking to work, was forced into a billiard hall by a man named Marlon. There, she was made to drink alcohol until she became disoriented. She was later brought to a room where she was sexually assaulted first by Marlon and then, upon regaining consciousness, by the appellant. AAA testified that she identified appellant by moonlight, resisted by kicking him, and was bitten on the arm. She reported the incident and was medically examined two days later, which revealed vaginal bleeding, a deep-healed hymenal laceration, and physical injuries on her arm and neck.
The defense presented only the appellant, who denied the allegations. He claimed he met AAA briefly at the billiard hall that night but left later, suggesting her accusation was part of a scheme to extort money. The Regional Trial Court convicted appellant of rape and sentenced him to reclusion perpetua, awarding civil indemnity and moral damages. The Court of Appeals affirmed the conviction but modified the damages to include exemplary damages.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for rape beyond reasonable doubt.

RULING

The Supreme Court dismissed the appeal and affirmed the conviction. The Court upheld the consistent findings of the trial and appellate courts regarding the credibility of AAA’s testimony. It emphasized the well-settled rule that the trial court’s assessment of witness credibility is accorded the highest respect, as it is in the best position to observe demeanor, and such findings are binding on appeal absent any showing of overlooked facts or circumstances. The minor inconsistencies in AAA’s testimony were deemed negligible and did not detract from the core consistency of her narrative of the assault.
The Court also rejected appellant’s argument that the medico-legal finding of a “deep-healed laceration” two days post-incident negated the rape. It reiterated that medical evidence is merely corroborative and not indispensable for a rape conviction, which can be established by the credible testimony of the victim alone. The presence of vaginal bleeding and other physical injuries corroborated AAA’s account. The defense of bare denial was deemed inherently weak and could not prevail over AAA’s positive, categorical, and credible identification of appellant as her assailant. Thus, all elements of rape through force and intimidation were proven beyond reasonable doubt.