GR 55028; (August, 1981) (Digest)
G.R. No. L-55028 August 31, 1981
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSE TEJADA, accused-appellant.
FACTS
The accused-appellant, Jose Tejada, was a neighbor and relative of the Talvo family. In October 1975, he invited the 17-year-old complainant, Florenda Talvo, to attend his sister’s wedding in another town, securing permission from her mother. They traveled together and stayed at his mother’s house. In the early morning before the wedding, Florenda testified that she was awakened by Tejada, who threatened her with a sharp instrument. He then forcibly had sexual intercourse with her despite her resistance. She reported the incident to Tejada’s brother later that day but only disclosed it to her own family a week later, out of fear.
A medical examination confirmed recent lacerations on Florenda’s hymen. Tejada denied the accusation, presenting witnesses including his niece, Aurora Tejada, who claimed she was with Florenda the entire night. The trial court convicted Tejada of rape and sentenced him to life imprisonment, leading to this appeal.
ISSUE
The core issue is the credibility of the complainant’s testimony versus the defense’s denial and alibi.
RULING
The Supreme Court affirmed the conviction. The ruling hinges on the well-established doctrine that the trial court’s assessment of witness credibility is accorded great weight and respect, especially in rape cases where the testimony of the victim is often the sole evidence. The Court found Florenda’s narration of the incident to be natural, straightforward, and corroborated by medical evidence. Her delay in reporting was reasonably explained by her fear and the accused’s familial relation.
Conversely, the defense witnesses were deemed unreliable. The testimony of the accused’s niece, Aurora Tejada, was rejected by the trial court as biased and untruthful, springing from her desire to shield her uncle. The Court upheld this finding, noting that the testimony of relatives is inherently suspect. The appellant’s denial could not overcome the positive and credible identification by the victim. Therefore, the prosecution proved his guilt beyond reasonable doubt.