G.R. No. L-46204. November 29, 1984. PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RUDY BELARMINO, defendant-appellant.
FACTS

On January 29, 1973, 16-year-old Elsie Besande and her friend Marina Ecaranum, 15, were passengers on a bus driven by Rudy Belarmino, bound for Camp 9, Libona, Bukidnon. After other passengers disembarked, Belarmino and his conductor, Romeo Reconoce, diverted the bus to a remote area. Reconoce made advances toward Marina, causing her to jump from the moving bus and escape after a struggle. Belarmino prevented Elsie from following, accelerated the bus, and drove to an isolated spot. There, despite her screams and physical resistance, Belarmino forcibly had sexual intercourse with her, causing vaginal lacerations. He then took her to a relative’s house, threatened her, and later brought her to Cagayan de Oro City, where she managed to escape and report the crime to the police. A medical examination confirmed recent sexual intercourse and physical injuries.
The accused, Rudy Belarmino, admitted to sexual intercourse but claimed it was consensual, alleging it occurred in a house, not in the bus. The trial court convicted him of rape, sentencing him to imprisonment for the rest of his natural life, not exceeding thirty years, and ordering him to indemnify the victim.

ISSUE

Whether the trial court erred in convicting the accused of rape based on the credibility of the complainant’s testimony and the sufficiency of the evidence proving carnal knowledge through force and intimidation.

RULING

The Supreme Court affirmed the conviction but modified the penalty and indemnity. The Court upheld the trial court’s assessment of the complainant’s credibility, finding her testimony clear, consistent, and corroborated by medical evidence of fresh lacerations and the presence of spermatozoa. Her immediate report to authorities and the harrowing sequence of events, including her friend’s escape, bolstered her account. The Court dismissed the alleged inconsistencies between her sworn statement and court testimony as minor details that did not undermine the core narrative of forcible intercourse. In contrast, the appellant’s defense of consent was deemed inherently improbable and unsupported by evidence. The legal logic rests on the principle that in rape cases, the complainant’s testimony, if credible and consistent with human experience, is sufficient to sustain a conviction. The Court modified the penalty to reclusion perpetua, as the imposed term was legally imprecise, and increased the civil indemnity to P30,000.00. The decision was affirmed with modifications.