G.R. No. 217804, September 2, 2015
Roldan Carrera, Petitioner, vs. The People of the Philippines, Respondent.

FACTS

Petitioner Roldan Carrera was charged with rape by sexual assault under Article 266-A(2) of the Revised Penal Code. The Information alleged that on June 13, 2004, in Barotac Viejo, Iloilo, Carrera, by means of force, threat, or intimidation, inserted his finger into the vagina of the victim, AAA, against her will. During trial, AAA testified that while walking home on a rainy evening, Carrera suddenly emerged, threatened to kill her, dragged her near a church, pinned her down, pulled down her shorts and panty, and inserted his finger into her vagina as she struggled and shouted. She escaped and ran home, where her mother reported the incident. A medical examination revealed fresh complete hymenal lacerations. Carrera denied the accusation, claiming alibi—that he was at a burial in another town, returned home by 5:00 p.m., joined a drinking session, and was asleep by 7:30 p.m. when arrested. The Regional Trial Court (RTC) convicted Carrera, sentencing him to an indeterminate penalty. The Court of Appeals (CA) affirmed the conviction with modifications, ordering Carrera to pay civil indemnity, moral damages, and exemplary damages. Carrera appealed to the Supreme Court, arguing that the prosecution failed to prove force, lack of voluntariness, and corroborating physical evidence.

ISSUE

Whether the prosecution proved Carrera’s guilt for rape by sexual assault beyond reasonable doubt, particularly regarding the element of force or intimidation and the credibility of AAA’s testimony.

RULING

The Supreme Court denied the petition and affirmed the CA Decision and Resolution. The Court held that the prosecution established Carrera’s guilt beyond reasonable doubt. AAA’s credible and consistent testimony detailed how Carrera used force and intimidation—threatening to kill her, dragging her, pinning her down, and overcoming her resistance—which constituted the element of voluntariness being absolutely lacking. The medical findings of fresh hymenal lacerations corroborated her account. The Court emphasized that factual findings of trial courts, affirmed by the CA, are generally binding unless shown to be arbitrary or unsupported. Carrera’s defenses of alibi and denial were weak compared to AAA’s positive identification. The penalty imposed by the RTC, as modified by the CA, was proper, and the awards of civil indemnity, moral damages, and exemplary damages were sustained in accordance with prevailing jurisprudence.