GR L 38644; (September, 1983) (Digest)
G.R. No. L-38644 September 30, 1983
People of the Philippines, plaintiff-appellee, vs. Vicente Mostoles, Jr. and Salvador de Guzman, Jr., accused-appellants.
FACTS
The appellants, Vicente Mostoles, Jr. and Salvador de Guzman, Jr., along with three others, were charged with forcible abduction with rape and robbery. The case stemmed from the complaint of Myrna Salazar, who alleged that around midnight of February 13, 1972, while walking home in Carmen, Rosales, Pangasinan, she was forcibly taken by a group of men in a tricycle. She was brought to an irrigation ditch in Barrio Tomana, where five men, including the appellants, successively raped her after tearing her clothes, pinning her down, and assaulting her. She reported the incident to police at dawn, leading to the arrest of the appellants. Medical examination confirmed recent sexual intercourse and physical injuries consistent with her account. During trial, the court dismissed the case against one co-accused for insufficiency of evidence, but convicted the appellants of multiple rape.
The appellants challenged their conviction, arguing that the lone testimony of the complainant failed to establish guilt beyond reasonable doubt. They highlighted alleged inconsistencies in her various statements regarding minor details, such as the exact sequence in which the accused assaulted her and whether she was boxed before being undressed. Appellant Mostoles also claimed the sexual act was consensual. The prosecution relied on Salazar’s direct testimony, her immediate report to authorities, her emotional identification of the appellants at the police station, and the corroborative medical findings.
ISSUE
Whether the testimony of the complainant, despite alleged inconsistencies on minor details, is sufficient to prove the guilt of the appellants beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction, holding that the alleged inconsistencies in the complainant’s testimony pertained to inconsequential details and did not undermine her overall credibility. The Court emphasized that in cases of multiple rape involving several assailants, a victim in a state of shock and distress cannot be expected to recall with perfect precision the exact sequence of events or every minor action. The core narrative of abduction and successive rape by the identified assailants remained consistent across her sworn statement, preliminary investigation testimony, and court declaration. Her immediate report to the police, the physical evidence from the medical examination, and her spontaneous identification of the appellants at the police headquarters strongly corroborated her account. The claim of consensual intercourse was rejected as contrary to the evidence of force and the complainant’s conduct. The Court ruled that the testimony of a single witness, if credible and positive, is sufficient for conviction, especially when the details of the crime are narrated in a straightforward manner and are consistent on the principal facts. The trial court’s assessment of credibility was thus upheld.
