GR 89370 72; (May, 1991) (Digest)
G.R. Nos. 89370-72. May 15, 1991.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PAULINO MAGDADARO Y GERONA, accused-appellant.
FACTS
The accused-appellant, Paulino Magdadaro, was convicted by the Regional Trial Court of Cagayan de Oro City for three counts of rape against Beverlinda Abrasado, the 16-year-old daughter of his tenant. The incidents allegedly occurred on July 10, July 15, and August 21, 1988. Beverlinda testified that on each occasion, Magdadaro used force, boxing her in the stomach and causing her to lose consciousness before sexually assaulting her. The third incident was witnessed by her father, Leonardo Abrasado, who discovered Magdadaro in the act. Magdadaro fled, leaving behind his pants and underwear at the scene. He was later found hiding nearby. Beverlinda’s medical examination revealed hymenal lacerations suggestive of sexual intercourse.
ISSUE
The core issue is whether the prosecution evidence sufficiently established the crime of rape, overcoming the accused’s defense of consensual sexual intercourse.
RULING
The Supreme Court affirmed the conviction. The Court found Beverlinda’s testimony credible and consistent. Her account was corroborated by physical evidence, including the clothing Magdadaro left behind during his flight on August 21, which strongly indicated a hurried escape inconsistent with a consensual act. Magdadaro’s flight upon discovery and his subsequent silence when confronted by authorities were deemed indicative of guilt. The Court applied the principle that silence in the face of a direct accusation can be considered a quasi-confession, as an innocent person would typically offer an immediate denial. Furthermore, Magdadaro’s repeated offers to settle the case with the victim’s father were correctly treated as implied admissions of guilt under the Rules of Court. Minor discrepancies between Beverlinda’s testimony and her affidavit were deemed inconsequential, as affidavits are often incomplete. The defense of consensuality was thoroughly discredited by the evidence of force, the victim’s distress, and the accused’s conduct. The penalty of reclusion perpetua for each count was upheld, though the civil indemnity was reduced to P30,000.00.