G.R. No. 66039, June 8, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLLY VILLAFLORES, accused-appellant.

FACTS

On September 2, 1975, in Barrio Cappit, Kasibu, Nueva Vizcaya, complainant Wilhelmina Ramel was alone in her kaingin when accused-appellant Rolly Villaflores approached her from behind. He forcibly embraced her, covered her mouth, and brought her to the ground. Threatening her with a bolo pointed at her breast, he warned her not to shout. He then removed her clothing, positioned himself on top of her, and consummated the sexual act. Afterward, he threatened to kill her if she reported the incident. Crying, she immediately reported the rape to her husband. They sought the Barangay Captain, but no settlement was reached due to Villaflores’s denial. Complainant underwent a medical examination which confirmed the presence of spermatozoa, and a formal complaint for rape was subsequently filed.
The defense presented a starkly different narrative. Villaflores denied the rape, claiming that on the same morning, the complainant had merely visited his farm to ask for money. He asserted that they had been lovers since before their respective marriages, resulting in a child who had died, and that she had undergone two abortions. He insinuated the complaint arose from a soured illicit relationship, not from a violent assault.

ISSUE

Whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the complainant’s testimony to be credible, straightforward, and consistent with human experience. The alleged inconsistencies in her testimony—such as whether the accused removed his pants or merely unzipped them—were deemed minor and immaterial, and were understandable given the traumatic circumstances of the assault. The Court emphasized that a victim struggling against an attack cannot be expected to recall every precise detail, and such minor variances do not undermine credibility but rather enhance it by showing the absence of rehearsed testimony.
The defense of a prior consensual relationship was rejected for lack of credible corroboration and for being inherently improbable. The Court found no credible motive for the complainant to fabricate a charge of rape, undergo a medical examination, and endure the humiliation of a public trial if the act had been consensual. Her immediate report to her husband and the authorities was consistent with the conduct of a true victim. The medical certificate corroborating recent sexual intercourse, coupled with the credible narrative of force and intimidation, established guilt beyond reasonable doubt. The trial court’s decision was affirmed, with the modification of increasing the indemnity to the offended party to P30,000.00.