GR 83947; (September, 1990) (Digest)
G.R. No. 83947 , September 13, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOMINADOR PARINGIT, accused-appellant.
FACTS
The case involves the rape of Nida Pajar, a married woman, in her hut in Barangay San Vicente East, Asingan, Pangasinan, at dawn on October 15, 1985. Nida testified that while breastfeeding her baby, the accused, Dominador Paringit, entered, embraced her, covered her mouth, punched her stomach, and then forcibly had carnal knowledge of her. She reported the incident to her husband upon his return. They promptly reported the crime to the barangay captain and the police, and Nida underwent a medical examination. The defense presented an alibi, with witnesses claiming the accused was playing poker at a wake in San Vicente West, approximately 500 meters away, from the night of October 14 until 5:00 a.m. on October 15. The accused also suggested the victim may have mistaken him for another person.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt, overcoming his defense of alibi and challenging the credibility of the victim’s testimony.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the complainant is paramount in rape cases. Nida Pajar’s straightforward and consistent testimony, including her immediate reporting of the crime and submission to medical examination, was found credible and sufficient to establish the elements of rape. The Court dismissed the defense’s arguments regarding minor inconsistencies in her narration and the medical findings. It clarified that the absence of spermatozoa or fresh lacerations does not negate rape, as penetration, not ejaculation, is the essential element. The medical report indicating a lax vaginal canal and old lacerations was deemed consistent with a mother of three and did not disprove recent sexual intercourse. The defense of alibi was rejected for failing to demonstrate the physical impossibility for the accused to be at the crime scene, given the short distance of 500 meters between the wake and the victim’s hut. The Court found no ill motive for the victim to falsely accuse the appellant. Consequently, the trial court’s judgment imposing reclusion perpetua and moral damages was upheld.