GR 37678; (April, 1976) (Digest)
G.R. No. L-37678. April 30, 1976.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RUSTICO ABAY, defendant-appellant.
FACTS
The prosecution established that on the night of May 17, 1971, appellant Rustico Abay, armed with a gun and aided by two companions, forcibly abducted 18-year-old waitress Lydia Casaul from España, Manila. Threatened with death, she was taken in a taxi to a secluded area near the seashore and later to a locked room. There, Abay forced her to drink a beverage that caused dizziness, overcame her physical resistance by striking her, and succeeded in having carnal knowledge against her will. The following day, Lydia was found by her aunt near Quiapo Church in a disheveled, traumatized state, her dress torn. She was immediately subjected to medical and legal scrutiny.
The medico-legal examination confirmed a recent, forceful sexual intercourse. A psychiatrist diagnosed Lydia with “re-active depression” stemming from a harrowing experience, noting her detailed, emotional recounting of the abduction and rape during therapy. The National Bureau of Investigation subsequently apprehended Abay. In his defense, Abay claimed the sexual act was consensual, alleging they were sweethearts, a claim contradicted by the victim’s consistent narrative and the physical and psychological evidence of force.
ISSUE
Whether the prosecution proved beyond reasonable doubt that appellant Rustico Abay committed the crime of Forcible Abduction with Rape.
RULING
Yes, the Supreme Court affirmed the conviction. The resolution hinged on the credibility of the complainant, which the Court found to be unwavering and corroborated by objective evidence. The Court rejected the defense of consensual relations, noting the inherent improbability of the victim willingly submitting given the circumstances of her abduction at gunpoint, her immediate distressed condition when found, and the medical proof of forcible defloration. The psychiatric finding of re-active depression directly resulting from the traumatic event further bolstered her testimony, as it explained any initial reticence or incoherence.
The legal logic applied the well-settled doctrine that the testimony of a rape victim, if credible, is sufficient to sustain a conviction. The Court emphasized that a young Filipina would not publicly allege rape, endure the ordeal of a trial, and reveal such dishonor unless motivated by truth. The trial court’s assessment of witness credibility was accorded great respect. However, the Court modified the civil indemnity, increasing it from P6,000 to P12,000 in accordance with the prevailing jurisprudence on rape indemnification at the time. Thus, the judgment of the Court of First Instance convicting Rustico Abay of Forcible Abduction with Rape and sentencing him to reclusion perpetua was affirmed with the stated modification.
