G.R. No. 231013 . January 29, 2020.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. PIO SALEN, JR. Y SENA, ACCUSED-APPELLANT.

FACTS

On December 28, 2010, AAA boarded a jeepney in Manila to go to work. She was the lone passenger, and the jeepney was driven by accused-appellant Pio Salen, Jr. y Sena. Instead of taking her to her destination, Salen drove past it, proceeding to a grassy area in Montalban, Rizal. There, he pointed a screwdriver at AAA, ordered her to have sex with him, and when she resisted and tried to wrestle the screwdriver away, he stabbed and slapped her, breaking her nose. He then raped her. Afterward, he stabbed and beat her again and took her belongings, including cash, a cellphone, and identification cards. AAA played dead until Salen left, then crawled for help and was brought to a clinic. A medico-legal examination confirmed injuries consistent with sexual abuse and physical assault. Salen was charged with Robbery with Rape under Article 294 of the Revised Penal Code. During trial, Salen claimed the sexual intercourse was consensual and denied robbing AAA. The Regional Trial Court found him guilty beyond reasonable doubt and sentenced him to reclusion perpetua without parole, ordering him to pay damages and return the stolen items. The Court of Appeals affirmed the conviction but increased the exemplary damages. Salen appealed to the Supreme Court, arguing that the victim’s testimony was improbable and that the trial court was biased.

ISSUE

Whether or not accused-appellant Pio Salen, Jr. y Sena is guilty beyond reasonable doubt of the crime of robbery with rape.

RULING

Yes, the Supreme Court affirmed the conviction. The prosecution sufficiently established all elements of robbery with rape: (1) the taking of personal property with violence or intimidation; (2) the property belonged to another; (3) the taking was with intent to gain; and (4) the robbery was accompanied by rape. The Court found the testimony of the victim, AAA, to be clear, straightforward, and credible. Her positive identification of Salen, corroborated by the medico-legal findings of her physical injuries and healed hymenal lacerations, constituted proof beyond reasonable doubt. The Court rejected Salen’s defense of consensual sex and denial as self-serving and unsubstantiated. It also held that the trial court’s assessment of witness credibility, affirmed by the Court of Appeals, is entitled to great respect. The Court emphasized that a victim’s testimony alone, if credible, is sufficient to sustain a conviction, and that survivors of rape cannot be blamed for their reactions during the assault. The penalties and awards of damages imposed by the lower courts were upheld.