G.R. No. 93732 November 21, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAMON CARSON, accused-appellant.

FACTS

The prosecution alleged that on September 21, 1985, in Alangalang, Leyte, accused-appellant Ramon Carson, a neighbor, raped 14-year-old Marilyn Barola. While Marilyn was minding her family’s store alone, Carson entered, produced a small bolo, threatened her, and forcibly dragged her to an upstairs room where he had carnal knowledge against her will. The act was interrupted when Marilyn’s sister, Gloria Caones, arrived. Marilyn immediately reported the assault, showing signs of distress, and was medically examined that same night, with findings consistent with sexual assault. The defense presented a contradictory version, claiming Marilyn was his sweetheart and the sexual act was consensual, though he provided no corroborating evidence for this relationship.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Carson committed rape through force and intimidation.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of the complainant credible and consistent. The medical certificate, indicating a hematoma on her neck and hymenal laceration, corroborated her account of a violent assault. The immediate reporting of the crime to her family, the swift medical examination, and the filing of a complaint strongly indicated a genuine desire for justice, not a fabricated story. The Court rejected the sweetheart defense as unsupported and noted that even if true, it is not a license for non-consensual sex. Minor inconsistencies in the testimonies of the complainant and her sister were deemed natural for provincial witnesses recounting a traumatic event and indicated a lack of rehearsal. The trial court’s assessment of witness credibility was accorded great respect. The decision was affirmed with modification, increasing the award of moral damages to P30,000.00.