GR 57737; (January, 1991) (Digest)
G.R. No. L-57737. January 28, 1991. THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JUAN ESTOLANO, accused-appellant.
FACTS
Accused-appellant Juan Estolano, a household helper, was convicted of rape by the Circuit Criminal Court and sentenced to reclusion perpetua. The prosecution evidence, primarily the testimony of complainant Rosalinda Dy, a married public school teacher, established that in the early morning of October 1, 1976, she was awakened in her bedroom by a man who threatened her with a knife, forcibly removed her underwear, and had carnal knowledge of her against her will. Only after the act, when the assailant used a flashlight, did she recognize him as Estolano. She immediately reported the rape to her brother-in-law, who alerted the police.
The defense presented a diametrically opposed version. Estolano claimed he and Rosalinda were lovers and that the sexual intercourse on October 1 was consensual, purportedly one of over twenty such encounters over a span of weeks. He asserted the relationship began when Rosalinda allegedly made advances towards him.
ISSUE
The core issue is one of credibility: whether the sexual intercourse was accomplished through force and intimidation, constituting rape, or was a voluntary act between consenting adults.
RULING
The Supreme Court affirmed the conviction, upholding the trial court’s assessment of credibility in favor of the complainant. The Court found the defense narrative inherently improbable and replete with inconsistencies when weighed against human experience and the established facts. Key improbabilities noted included: the alleged affair’s inception under implausible circumstances; the conduct of numerous illicit trysts in a cramped bedroom shared with the complainant’s seven children and a helper, with the constant risk of discovery; the claim of a two-hour intercourse on the night in question; and Estolano’s unnatural behavior of remaining in the room when the complainant’s child awoke. The Court also drew an unfavorable inference from apparent defense tactics to delay the trial.
In contrast, Rosalinda Dy’s testimony was found to be straightforward, consistent, and corroborated by her prompt reporting of the crime. The Court found no motive for a respectable married woman and mother to falsely accuse a household helper and expose herself and her family to scandal. Consequently, the trial court correctly rejected the defense of a love affair as a mere fabrication. The Court modified the judgment only by increasing the indemnity awarded to the victim from P12,000 to P30,000.00, consistent with prevailing jurisprudence.