G.R. No. L-31243-44 October 28, 1977
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALFREDO RAPADA Y CARLO, defendant-appellant.

FACTS

The accused-appellant, Alfredo Rapada, was charged with two counts of rape against complainant Nora Reyeg. The prosecution’s evidence, as summarized by the trial court, established that on February 19, 1968, Rapada entered Reyeg’s house in Bicutan, closed the door, pushed her down, and through force and intimidation—specifically by threatening to kill her while holding a knife—had carnal knowledge of her. He repeated the act on February 20, 1968, after boxing her twice in the stomach. Reyeg, who was 24, had only finished second grade, suffered from polio, and was described as appearing mentally deficient, reported the incidents to her sister after being threatened not to do so.
The defense presented a diametrically opposed version. Rapada claimed that the sexual intercourse on both occasions was consensual. He testified that he and Reyeg had developed a relationship after meeting earlier in February, and that she had invited him to stay and sleep in her house. He denied using any force, threat, or intimidation, and asserted that the acts were voluntary. He also alleged that any extra-judicial admission was obtained through police maltreatment.

ISSUE

The core issue is whether the trial court erred in its appraisal of the evidence, leading to the conviction of the accused for two counts of rape, despite the defense of consent and the challenge to the voluntariness of an extra-judicial admission.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in rape cases where the versions of the prosecution and defense are in direct conflict, the factual findings and credibility assessments of the trial court are accorded great weight and respect. The trial court, having observed the witnesses firsthand, found the testimony of the complainant to be credible and consistent. The Court noted the complainant’s mental deficiency and physical handicap, which made her testimony of force and intimidation more believable and rendered the defense of consent implausible.
Regarding the extra-judicial admission, the Court applied the principle that even if a confession is deemed involuntary and improperly admitted, a conviction can still stand if there is other sufficient evidence to establish guilt beyond reasonable doubt. In this case, the complainant’s direct and credible testimony provided ample basis for the conviction, independent of any contested admission. The defense’s claim of consent was effectively rebutted by the evidence of force and the complainant’s vulnerable condition. The penalty of reclusion perpetua for each offense was affirmed, with modifications for full credit of preventive imprisonment and the imposition of indemnity.