G.R. No. 92124; May 6, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. OSCAR BASE, ALFREDO BASE, ROGER CARIÑO, ROQUE CARIÑO, and JOHN DOE, defendants. OSCAR BASE, ALFREDO BASE and ROQUE CARIÑO, defendants-appellants.

FACTS

The appellants, along with others at large, were charged with Robbery with Multiple Rape. The prosecution evidence established that on the evening of September 6, 1988, the accused forcibly entered the isolated dwelling of spouses Domingo and Vilma Bista in Rapu-Rapu, Albay. Oscar Base, armed with a gun, and Alfredo Base, along with Roque and Roger Cariño, armed with bolos, carried out the robbery. During the incident, Oscar Base raped Vilma Bista at gunpoint. Subsequently, the kerosene lamp was extinguished, and a second man, identified by the victims as Alfredo Base, also raped her. The husband was rendered helpless by the armed Cariño brothers. The crime was promptly reported to authorities.
The defense interposed alibis. Oscar and Alfredo Base claimed they were fishing at the time, while Roque Cariño presented a different story but corroborated the Bases’ absence. The trial court convicted the appellants, finding the testimonies of the victims credible and noting the immediate reporting of the crime. The court also held that the absence of a medical examination did not negate the rape, as the doctor had declined to examine the married victim days after the incident.

ISSUE

The core issue is whether the guilt of the appellants for the complex crime of Robbery with Multiple Rape was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The legal logic rests on the credibility of the victims’ positive identification and the establishment of conspiracy. The Court found no reason to disturb the trial court’s assessment of witness credibility, which is accorded high respect. The spouses gave consistent, straightforward, and convincing accounts of the traumatic event, which were corroborated by their immediate report to the barangay captain. The defense of alibi was properly rejected for being weak and unsubstantiated.
Regarding the rape charges, the Court ruled that medical examination is not indispensable for conviction. The victim’s credible testimony alone can suffice. Here, the failure to obtain a medico-legal report was reasonably explained by the unavailability of a doctor on the island and the subsequent refusal of a provincial hospital doctor to examine a married woman days after the alleged assault. The Court also found conspiracy from the appellants’ collective and coordinated actions—the armed intrusion, the division of roles between robbery and intimidation, and the sequential sexual assaults—which demonstrated a common criminal purpose. Consequently, all conspirators are liable as co-principals for the acts executed pursuant to the conspiracy, including the multiple rapes committed during the robbery. The award of moral damages was sustained due to the heinous nature of the crime.