GR 95680; (October, 1991) (Digest)
G.R. No. 95680 October 4, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO NGO, accused-appellant.
FACTS
The accused-appellant, Rodolfo Ngo, and the private complainant, Josefina Gracia Damgo, were sweethearts for five years and had planned to marry. The complainant ended the relationship in March 1983 due to the accused’s infidelity and religious differences. On the evening of March 26, 1983, the complainant alleged that while on her way to church, she was forcibly abducted by the accused and three other men. She was taken to an uninhabited area where the accused and his companions successively raped her.
The defense presented a different account. The accused claimed the sexual relations between him and the complainant were consensual, occurring prior to the breakup. He alleged the complainant filed the case out of spite after he called off the wedding upon learning she was no longer pregnant. He also presented an alibi, stating he was drinking and later sleeping with another woman at a country club at the time of the alleged incident.
ISSUE
The core issues were: (1) whether the crime of rape occurred, and (2) whether the accused-appellant was positively identified as one of the perpetrators.
RULING
The Supreme Court affirmed the conviction. The Court applied established doctrines in rape cases. First, the testimony of the victim, if credible, is sufficient to sustain a conviction. Second, the Court recognized that no woman of decent repute would willingly admit to a violation of her chastity unless it was the truth, as doing so subjects her to public humiliation and scorn. The complainant’s detailed and consistent testimony on the forcible abduction and rape was found credible.
The Court rejected the defense’s theory of fabrication for revenge. It noted the complainant’s upstanding character as a church leader and community figure, which made it highly improbable she would fabricate such a grave charge. The alibi was dismissed for being weak and unsubstantiated. The positive identification by the victim, who knew the accused intimately for years, prevailed over the denial and alibi. The trial court’s findings on credibility were accorded great weight. The penalty of reclusion perpetua was affirmed, with the civil indemnity increased to P40,000.00.