G.R. No. 58847 August 31, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BARTOLOME BARRANCO, accused-appellant.

FACTS

The case involves the rape of Rosalia Barranco, a 19-year-old woman, by her relative and neighbor, Bartolome Barranco. On February 10, 1980, while Rosalia was alone and asleep in her house, Bartolome entered, undressed, and placed a butcher’s knife to her neck. He threatened to kill her if she moved or shouted. Despite her resistance, Bartolome forcibly succeeded in having carnal knowledge of her. Rosalia, paralyzed by fear, did not immediately report the crime. On March 19, 1980, Bartolome attempted to assault her again. This time, Rosalia fought back by hitting him with a piece of wood and threatening to shout for help, causing him to flee. She then confessed the February rape to her mother, leading to a medical examination which confirmed sexual intercourse and pregnancy. A complaint was filed.
The accused was convicted of rape with the use of a deadly weapon by the trial court and sentenced to reclusion perpetua. The court also ordered him to recognize the child born from the rape as his own. Bartolome appealed, contesting the credibility of Rosalia’s testimony due to the lack of corroboration, the delay in reporting the crime, and the absence of physical injuries or torn clothing. He also argued against the penalty and the order to recognize the child.

ISSUE

The primary issues are: (1) whether the prosecution proved the crime of rape beyond reasonable doubt; and (2) whether the trial court erred in ordering the accused to recognize the offspring as his legitimate child.

RULING

The Supreme Court affirmed the conviction but modified the civil liabilities. The Court upheld the credibility of Rosalia’s testimony, which was clear, consistent, and convincing. It explained that rape is inherently a private crime, rarely witnessed by others. The delay in reporting and the absence of physical struggle or torn garments were satisfactorily explained by the victim’s overwhelming and continuing fear of the accused, who was a relative, a neighbor, and had threatened her life with a knife. Her subsequent courageous resistance during the second attempt, which finally prompted her to report the first rape, made her account more credible, not less. The medical findings corroborated sexual intercourse.
Regarding the penalty, the Court affirmed the imposition of reclusion perpetua, as the death penalty was constitutionally prohibited. However, the Court corrected the trial court’s order for the accused to recognize the child. Citing applicable jurisprudence and law, the Court held that a married man, like Bartolome, cannot be compelled to recognize a child born out of adultery as his legitimate offspring. Nevertheless, he has the legal obligation to provide support for the child. The Court also increased the civil indemnity awarded to the victim to P30,000.00. Thus, the conviction was affirmed with modifications to the civil aspects of the judgment.