GR 91619; (September, 1996) (Digest)
G.R. No. 91619 September 9, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GAVINO L. PASAYAN, accused-appellant.
FACTS
The prosecution established that on April 8, 1987, accused-appellant Gavino Pasayan, a driver for Royal Star Marketing, invited his co-worker, Dolores Catimbang, to lunch. During the meal at a restaurant, Catimbang observed Pasayan pouring her softdrink. After eating, she felt dizzy upon boarding his jeep. She lost consciousness and awoke naked on a bed in a room at the Garden Inn Resort, with Pasayan beside her. She was bleeding from her private parts, felt pain, and realized she had been violated. When she fought back, Pasayan threatened her with a knife and forced himself on her again. Afterward, he warned her not to report the incident.
Catimbang stayed at a friend’s house until April 11, when her parents found her. They had her medically examined by Dr. Solita Plastina, who confirmed a fresh hymenal laceration. A witness, Moises Lemos, corroborated seeing Pasayan carrying an apparently unconscious Catimbang into the resort. The defense claimed they were sweethearts and the act was consensual, but provided no substantiation.
ISSUE
Whether the accused-appellant is guilty beyond reasonable doubt of the crime of rape.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimony of the victim to be credible, natural, and consistent with human experience. Her account of being drugged via her softdrink, losing consciousness, and awakening to find herself violated was corroborated by the medico-legal certificate showing a fresh laceration and by the witness who saw her being carried unconscious into the resort. Her subsequent distraught behavior, as testified to by her friend, further supported her lack of consent.
The legal logic rests on the well-established doctrine in rape cases that the accused may be convicted solely on the testimony of the complaining witness, provided it is credible and convincing. The Court held that Catimbang’s testimony met this standard, rendering the defense of a sweetheart theory unsubstantiated and implausible. Minor inconsistencies in a victim’s narrative do not destroy credibility, especially when the core allegation of forcible sexual intercourse is supported by medical and testimonial evidence. The trial court’s finding of guilt beyond reasonable doubt was upheld. The Court modified the award of civil indemnity, increasing it to Fifty Thousand Pesos (P50,000.00) in line with prevailing jurisprudence.