G.R. No. L-31886 April 29, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANCISCO ROYERAS alias Buyo, defendant-appellant.

FACTS

The prosecution evidence established that on October 2, 1967, in Barrio Maribi, Tanauan, Leyte, appellant Francisco Royeras, a second cousin and compadre of the victim’s husband, forcibly raped Eufrosina Almaden. While Eufrosina was walking alone, Royeras emerged from hiding, grabbed her, and despite her continuous struggle, overpowered her using his superior strength. He threatened her with a bolo, invoking his known reputation as a killer, which instilled fear and caused her to submit. He succeeded in having carnal knowledge of her. After the incident, Eufrosina immediately reported the outrage to her husband and subsequently to the authorities. A medical examination conducted hours later yielded a negative finding for sperm cells, with the doctor explaining this could be due to the lapse of time or external ejaculation.
The defense interposed by Royeras was denial and a claim of a consensual adulterous affair with the complainant. He alleged that the sexual encounter on the date in question was mutual and that the rape charge was fabricated after they were allegedly surprised by a third party. The trial court rejected this defense, finding the complainant’s testimony credible and consistent with human experience, while noting the inherent improbability of the defense story given the familial and compadre relationship between the parties.

ISSUE

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

RULING

The Supreme Court affirmed the conviction. The Court meticulously analyzed the evidence and found the testimony of the complainant to be credible, natural, and convincing. It held that her account of being suddenly attacked, physically overpowered, and threatened with a deadly weapon by a man known to have killed before adequately established the elements of force and intimidation necessary for rape. The Court explained that the negative medical finding for sperm cells did not negate the commission of rape, as the doctor’s testimony clarified that such a result was possible given the time lapse between the act and the examination, and the complainant’s own observation of semen on her thighs corroborated the external ejaculation. The Court reiterated the doctrine that full penetration, not internal ejaculation, consummates the crime of rape.
Furthermore, the Court ruled that the complainant’s testimony, being credible and consistent, required no corroboration to sustain a conviction. The defense of a fabricated charge arising from a supposed affair was deemed untenable and contrary to the ordinary conduct of a married woman in a close-knit rural community, especially considering the compadre relationship which made such an affair highly improbable. The Court found that the prosecution successfully proved all elements of the crime. The penalty of reclusion perpetua was affirmed, with the indemnity increased to Five Thousand Pesos.