GR L 47489; (June, 1987) (Digest)
G.R. No. L-47489, June 18, 1987
People of the Philippines vs. Eulogio Manaay
FACTS
Accused-appellant Eulogio Manaay was charged with two counts of rape against his housemaid, Marina Pacaoncis, allegedly committed on May 22 and June 27, 1968. After trial, the Court of First Instance of Rizal convicted him for the May 22 incident (Criminal Case No. 18600) but acquitted him for the June 27 incident (Criminal Case No. 18601) due to insufficient evidence. The prosecution’s version, as credited by the trial court, established that on May 22, 1968, Manaay lured the 18-year-old complainant into his room, used force and intimidation by slapping and hitting her, and succeeded in having carnal knowledge against her will. He threatened to kill her if she reported the incident. The complainant continued working in the household out of fear.
ISSUE
The core issue is whether the prosecution evidence, primarily the complainant’s testimony, was sufficient to prove the appellant’s guilt for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The legal logic centered on the credibility of the complainant’s testimony and the weakness of the defense. The Court emphasized that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction. The complainant withstood an exhaustive cross-examination over two years and four months, remaining consistent, precise, and firm. Her testimony was found to be devoid of material contradictions and inherently believable, detailing the force, intimidation, and subsequent threats employed by the appellant. The Court ruled that the absence of physical evidence, like a torn panty, is not fatal, as conviction rests on the totality of evidence, not a single item. Conversely, the appellant’s defense of alibi failed because he did not prove it was physically impossible for him to be at the scene of the crime at the time, nor did he show any ill motive for the complainant to falsely accuse him. The defense of alibi, being inherently weak, cannot prevail over the positive identification by a credible witness. The decision was modified only to order the appellant to indemnify the complainant in the amount of Twenty Thousand Pesos (P20,000.00) as civil liability.