GR 79896; (July, 1995) (Digest)
G.R. No. 79896. July 12, 1995.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DELFIN REYES y LAZARO, RODOLFO MACALINAO, DAN REYES and DODO REYES, accused-appellants.
FACTS
Accused-appellants Delfin Reyes, Rodolfo Macalinao, Dan Reyes, and Dodo Reyes were charged with the rape of Milagros Fabian. The prosecution evidence established that on August 17, 1982, the appellants arrived at the hut of spouses Luis and Milagros Fabian in Hagonoy, Bulacan. Delfin invited Luis to steal milkfish, and upon refusal, Delfin pointed a gun at Luis while Dan and Rodolfo tied his hands. Rodolfo, Dan, and Dodo then entered the hut, tied Milagros, tore her dress, and removed her underwear. They proceeded to rape her successively while Delfin guarded Luis with a gun. The following morning, the spouses reported the crime to the police, and a medical examination confirmed recent sexual intercourse.
ISSUE
The core issue is whether the trial court erred in convicting the accused-appellants based on the credibility of the prosecution witnesses, despite alleged inconsistencies in their testimonies.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, emphasizing that such factual findings are generally binding on appeal. The minor inconsistencies highlighted by the defense, such as the exact timing of the police report or specific details of the assault, were deemed inconsequential. The Court ruled that such variances are natural and may even indicate truthful, unrehearsed testimony. The victim’s clear and consistent narration of the traumatic event, including her courtroom re-enactment, was found credible. The defense counsel’s request for this re-enactment was noted as a tactical error that ultimately bolstered the prosecution’s case. The Court also found conspiracy duly established, making each appellant equally liable for the acts of the others. Consequently, the penalty of triple reclusion perpetua was sustained. The civil indemnity was increased to P50,000.00 for each count of rape, totaling P150,000.00, considering the aggravating circumstance of the victim being pregnant and assaulted in her husband’s presence.