GR L 44408; (September, 1982) (Digest)
G.R. No. L-44408 September 30, 1982
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ERNESTO SAMBILI, accused-appellant.
FACTS
The accused, Ernesto Sambili, was convicted of rape by the Court of First Instance of Quezon and sentenced to reclusion perpetua. The prosecution evidence established that on July 18, 1974, the complainant, Nemesis Almero, a married fish vendor, was walking home alone after selling fish. It was already dark when she noticed the accused following her. She ran but he chased her, caught her by the hair, covered her mouth, and dragged her to a forested area some distance from the road. There, he forcibly pulled down her clothing and had carnal knowledge of her against her will. After the first act, he dragged her further and raped her a second time. The complainant eventually escaped naked and sought immediate refuge at a nearby house, where she was given clothing and assistance.
ISSUE
The core issue is whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt, specifically concerning the commission of the crime and the positive identification of the accused as the perpetrator.
RULING
The Supreme Court affirmed the conviction, modifying the judgment to include an indemnity award. The Court found the complainant’s testimony credible, consistent, and corroborated by her immediate conduct after the incident—fleeing naked to a nearby house and reporting the assault. The defense of alibi and the insinuation of a consensual tryst were rejected. The Court held that the circumstances, including the forcible abduction, the complainant’s resistance, and her distressed state, were utterly inconsistent with a romantic encounter. Regarding identification, the Court ruled that the complainant had more than sufficient opportunity to recognize her assailant. She knew him by face prior to the incident, as his wife was her customer, and she had a clear view of him during the prolonged attack, which included two separate assaults. Her immediate and positive identification of the accused when presented with an opportunity was deemed spontaneous and reliable. The Court concluded that the evidence established all elements of rape through force and intimidation, and the accused’s identity as the perpetrator, beyond a reasonable doubt.