G.R. No. 234951, January 28, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. BENJAMIN A. ELIMANCIL, Accused-Appellant

FACTS

On the night of August 14, 2000, the victim, AAA, was alone in her boarding house in Mariveles, Bataan. She fell asleep with the lights on. Around 11:30 p.m., she was awakened when she felt someone lie beside her. She saw the accused-appellant, Benjamin Elimancil, whom she knew as a friend of her brother from their hometown, poking a knife at her left side. Elimancil threatened her not to shout. He then forcibly pulled down her pajama and panty while still holding the knife. AAA tried to resist but could only cry out of fear. Elimancil removed his pants and underwear, placed himself on top of her, forced his penis into her vagina, and made push-and-pull movements for more than a minute. AAA felt pain and cried until she felt a hot liquid from Elimancil’s penis. She saw blood in her vagina afterwards. Before leaving, Elimancil threatened her not to tell anyone. AAA reported the incident to her board-mate upon arrival and to her parents the next day. Her father sought police assistance. On August 17, 2000, a medical examination at Bataan Provincial Hospital by Dr. Neriza A. Paguio revealed superficial healed lacerations at multiple positions on AAA’s genitalia. An Information was filed charging Elimancil with Rape. At trial, Elimancil denied the accusation, claiming he was at AAA’s boarding house for a birthday party and that it was impossible to assault her without others hearing. The Regional Trial Court (RTC) found him guilty beyond reasonable doubt of Simple Rape under Article 266-A(1) of the Revised Penal Code, noting the aggravating circumstance of using a deadly weapon, and sentenced him to reclusion perpetua without eligibility for parole, plus damages. The Court of Appeals (CA) affirmed the RTC decision. Elimancil appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Benjamin A. Elimancil for the crime of Simple Rape.

RULING

No, the Court of Appeals did not err. The Supreme Court denied the appeal and affirmed the conviction. The Court applied the guiding principles in reviewing rape cases, emphasizing that the credibility of the complainant is paramount. It found AAA’s testimony to be credible, straightforward, spontaneous, and consistent with human nature. The medico-legal findings corroborated her claim of recent sexual intercourse. The Court upheld the factual findings of the RTC, as affirmed by the CA, noting that the trial court is in the best position to assess witness credibility and that no arbitrariness or misapprehension of facts was shown. The defense of denial and alibi could not prevail over the positive and categorical testimony of the victim. The elements of rape through force, threat, or intimidation were proven beyond reasonable doubt. The penalty of reclusion perpetua without eligibility for parole and the awards of civil indemnity, moral damages, and exemplary damages were sustained.