G.R. No. 93709 May 8, 1992
People of the Philippines, plaintiff-appellee, vs. Joseph Rabanes, alias Bado, defendant-appellant.

FACTS

The accused-appellant, Joseph Rabanes, was charged with rape for an incident occurring on September 15, 1989. The prosecution’s evidence, as summarized by the trial court, established that the complainant, Angelina Naallatan, was on her way home when Rabanes approached her, slapped her, squeezed her neck causing her to fall, and threatened her with a stone. After she lost consciousness from another slap, he raped her. She reported the incident to her sister-in-law, Belen Paclar, who then brought her to barangay kagawad Roman Ibajay. The accused was later apprehended and identified by the complainant. Medical examinations confirmed abrasions on her neck and forearm, and her hymen showed old, healed lacerations. A witness, Felicito Cabasan, testified to seeing the accused following the woman and hearing her cry for help, though he did not intervene. The defense version, presented solely by the accused, claimed that the sexual intercourse was consensual and pursuant to an agreement for P100.00. He testified he had been drinking beer that morning, approached and held the complainant thinking he knew her, and after a conversation, they agreed to have sex. The trial court convicted the accused, sentencing him to reclusion perpetua and ordering him to pay damages.

ISSUE

The primary issue is whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but deleted the award of exemplary damages. The Court held that the trial court correctly gave credence to the complainant’s testimony, which was clear, convincing, and consistent with human nature and the normal course of things. The medical findings of abrasions corroborated her claim of force and violence. The Court found the defense of consensual sex to be inherently improbable and noted the accused’s own testimony contained inconsistencies and admissions that undermined his claim. The Court rejected the accused’s arguments regarding the lack of spermatozoa in the vaginal smear (explaining its absence does not negate rape), the failure to present certain witnesses (not fatal to the prosecution’s case), and the consideration of a previous rape charge (though error, it did not affect the independent proof of guilt beyond reasonable doubt). The Court also found no mitigating circumstance of intoxication, as the accused admitted he was not drunk. However, the award of exemplary damages was deleted as no aggravating circumstance was proven.