G.R. No. L-44033 September 30, 1982
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FEDERICO BESO, JR. y BANGIBAN, defendant-appellant.

FACTS

The appellant, Federico Beso Jr., was convicted of two counts of rape by the Court of First Instance of Quezon City and sentenced to reclusion perpetua for each crime. The complainant, Erlinda Lachica, was an 18-year-old helper living in the appellant’s home. She testified that on November 9, 1974, the appellant, while his wife was out, pressed a pillow on her face, threatened to kill her, and forcibly had sexual intercourse with her three times. A second assault occurred on January 2, 1975, during which the appellant boxed her when she resisted, succeeding in having intercourse twice. Her torn pants and panty were presented as evidence. She escaped the next day and reported the incidents to her brother and then to the NBI, where a medico-legal examination confirmed physical injuries and findings consistent with recent sexual intercourse.
The defense presented a contradictory version, alleging a consensual romantic affair between the appellant and the complainant. The appellant claimed the bruises noted in the medical report were inflicted by the complainant’s brother upon learning of the affair. He also presented a teacher to attest to the complainant’s regular school attendance, attempting to refute her claim of being confined to the house after reporting the initial rape to the appellant’s wife.

ISSUE

The core issue is whether the prosecution proved the appellant’s guilt for the crime of rape beyond reasonable doubt, specifically overcoming the defense of a consensual relationship.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of credibility, giving utmost respect to its direct observation of the witnesses. The complainant’s detailed and consistent testimony on the use of force, threats, and violence was found credible and compelling. This testimony was strongly corroborated by the medico-legal findings of contusions on her body and evidence of recent sexual activity, which aligned with her account of the assaults.
The defense’s theory of a consensual affair was rejected as implausible and unsupported by credible evidence. The Court found the claim that the bruises were caused by the complainant’s brother to be contrived and inconsistent with the evidence. The alleged love letter was not presented, and the explanation for its absence was deemed unconvincing. The teacher’s testimony on school attendance was considered inconclusive and did not disprove the complainant’s narrative of restricted movement. The totality of the prosecution’s evidence solidly established the appellant’s guilt for two acts of rape committed through force and intimidation.