G.R. No. L-40621 August 21, 1982
The People of the Philippines, plaintiff-appellee, vs. Aquilino Padunan alias “Quilin”, accused-appellant.

FACTS

The prosecution’s evidence established that in the early morning of November 29, 1965, fifteen-year-old Estrella Ismael Vallejo arrived at the Caba, La Union train station. Appellant Aquilino Padunan, whom she knew, approached and offered to escort her home, claiming her uncle had instructed him. While walking along the railroad tracks, Padunan suddenly attacked her. He grabbed her hair, tied her hands behind her back with a handkerchief, and gagged her with her own torn panty. He then boxed her, pushed her to the ground, and succeeded in having carnal knowledge with her despite her struggles. After the act, he tied her feet and fled. The victim managed to free herself and immediately reported the assault to relatives and the police. A medical examination confirmed fresh hymenal lacerations consistent with recent sexual intercourse.
The defense presented a different account, claiming the sexual act was consensual. Padunan testified that he and the complainant were sweethearts and that they had engaged in sexual intercourse by the river that night after a conversation. He asserted she only filed the rape charge later because he refused her demand for money following the incident.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Aquilino Padunan had carnal knowledge of Estrella Ismael Vallejo through force and intimidation, thereby committing the crime of rape.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of the complainant to be credible, natural, and consistent with human experience. Her detailed account of the sudden and violent attack, her resistance evidenced by scratching the appellant, and her immediate reporting of the crime were persuasive indicators of truthfulness. The medical certificate corroborated her claim of a recent sexual assault. The Court rejected the defense of consensual intercourse as implausible, noting the inherent improbability of a young woman voluntarily submitting to sexual intercourse in the described location and manner, followed by immediate public disclosure and medical examination, merely due to a spurned request for money.
The Court also addressed minor discrepancies between the victim’s trial testimony and her prior affidavit, explaining that affidavits are often incomplete and are generally inferior to testimony given in open court under oath and cross-examination. The absence of a mention of certain details, like being scratched or boxed, in the affidavit did not discredit her consistent core narrative of rape. The penalty of reclusion perpetua was upheld. The Court additionally awarded moral damages to the victim, as the civil liability was deemed impliedly instituted with the criminal action.