GR L 44223; (August, 1984) (Digest)
G.R. No. L-44223, August 30, 1984
The People of the Philippines vs. Dominador Angsioko y Domondon
FACTS
The prosecution’s evidence established that on March 30, 1975, Zenaida Vecinal, an 18-year-old from Batangas, was traveling by bus to Bacoor, Cavite. Appellant Dominador Angsioko, seated in front of her, introduced himself. During a stop in Tagaytay, he offered her a bottle of 7-Up, which she reluctantly accepted out of fear. After drinking it, she felt dizzy, numb, and weak. Angsioko did not alert the driver to stop at her destination.
Angsioko instead brought the disoriented Zenaida to a house in Paco, Manila. Despite her resistance, she was physically helpless due to her condition. He forced her upstairs and sexually assaulted her. She regained consciousness the next morning, naked, in pain, and with contusions on her body and injuries to her private part. A subsequent medical examination confirmed recent healed lacerations on her hymen and various contusions. Angsioko later visited her home, promising to settle the matter, which delayed her formal complaint.
ISSUE
The core issue is whether the prosecution proved beyond reasonable doubt that the appellant committed rape against the complainant.
RULING
The Supreme Court affirmed the conviction. The Court found Zenaida’s testimony to be credible, consistent, and corroborated by the medico-legal findings. Her detailed account of being drugged, rendered helpless, and subsequently violated was deemed convincing. The medical report (Exhibit “B”) documented physical injuries, including recently healed hymenal lacerations, which were consistent with her allegation of recent sexual intercourse and the force applied.
The Court rejected the defense’s argument that the medical findings were not directly linked to the rape incident. Dr. Larion explicitly testified that he conducted the examination upon a police request “in connection with the charge of an alleged rape,” providing the necessary context. Furthermore, the Court reiterated that a medical examination, while corroborative, is not an indispensable element for a rape conviction. The credible and positive testimony of the victim, which withstood rigorous cross-examination, is sufficient to sustain a finding of guilt, especially when weighed against the appellant’s bare denial. The penalty of reclusion perpetua was upheld, and the civil indemnity was increased to P30,000.00.
