G.R. No. 71116 September 19, 1989
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. DIONISIO HORTILLANO, defendant-appellant.

FACTS

The accused-appellant, Dionisio Hortillano, was convicted by the Regional Trial Court of rape and sentenced to reclusion perpetua. The prosecution evidence established that on January 4, 1983, the 16-year-old complainant, Elsa Ancog, was walking home alone at dusk when she was accosted by Hortillano, whom she knew. He grabbed her, pointed a knife at her throat, and forcibly dragged her to a nearby hut. Inside, he threatened her with death if she shouted, tripped her onto a bamboo bed, forcibly removed her clothing, slapped her when she attempted to cry out, and succeeded in having carnal knowledge of her. Afterward, he threatened to kill her if she reported the incident.
Complainant did not immediately disclose the rape to her parents out of fear. Her pregnancy was later discovered by her aunt in May 1983, prompting her to reveal the assault. A medical examination confirmed her pregnancy and physical findings consistent with sexual intercourse. The defense presented an alibi, claiming he was elsewhere, and alleged that the sexual encounters were consensual and for a fee, arguing that the complainant’s delayed reporting and composed demeanor in court cast doubt on her story.

ISSUE

The core issue is whether the prosecution proved the crime of rape beyond reasonable doubt, overcoming the defenses of alibi and alleged consensual relations.

RULING

The Supreme Court affirmed the conviction. The Court meticulously dismantled the appellant’s defenses. On the claim of consensual relations, the Court ruled that a victim’s prior sexual experience or lack of virginity is immaterial to the crime of rape, which is established by carnal knowledge through force or intimidation. The complainant’s credible and categorical testimony detailing the use of a knife, threats, and physical force sufficiently established these elements. Her initial silence, out of fear of the accused’s threats, is a natural reaction and does not undermine her credibility.
Regarding the alibi, the Court held it must be proven with clear and convincing evidence that the accused was at another place for the entire period such that it was physically impossible for him to be at the crime scene. The appellant’s own admission placed him in the vicinity at the time of the incident, thus failing to meet this stringent requirement. The minor discrepancy in the initial date of the incident in the affidavit was satisfactorily explained and corrected, constituting an inconsequential variance that does not affect the core facts of the crime. The trial court’s assessment of witness credibility is accorded great weight. Consequently, the Court upheld the penalty of reclusion perpetua but increased the civil indemnity to Thirty Thousand Pesos (P30,000.00) in line with prevailing jurisprudence.