G.R. No. L-48746. March 15, 1984.
THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JULIO CABANLIG, Accused-Appellant.

FACTS

The appellant, Julio Cabanlig, was convicted of rape by the Court of First Instance of Pangasinan and sentenced to reclusion perpetua. The complainant, 14-year-old Isabel Distor, testified that on the night of October 30, 1975, during a girl scout camping event in Barangay San Felipe, Binalonan, she was invited by two companions, Myrna Tadena and Paulina Bugaoan, to urinate. Instead, Myrna led them to a camarin owned by Cabanlig. After a short while, Myrna and Paulina left, ostensibly to urinate. Cabanlig then arrived, forcibly embraced and kissed Distor, pushed her onto a bamboo bed, and threatened her with a knife. He then had sexual intercourse with her twice, despite her pleas and resistance, and released her only at around 4:00 a.m. the next day.
Distor did not immediately report the incident due to fear of Cabanlig’s threats. The matter came to light days later when school teachers informed her father. During a confrontation before the barrio captain, Cabanlig admitted the act. Settlement talks ensued, including an agreement for marriage, which Cabanlig breached by marrying another woman, prompting the filing of the criminal case. The defense was denial and alibi, claiming Distor’s testimony was fabricated.

ISSUE

The core issue is whether the prosecution proved the crime of rape beyond reasonable doubt, particularly in light of the appellant’s challenges to the credibility of the complainant’s testimony.

RULING

The Supreme Court affirmed the conviction. The Court meticulously addressed the appellant’s arguments attacking the credibility of Isabel Distor’s testimony. It held that minor inconsistencies, such as the initial non-mention of a knife in her sworn statement versus her court testimony, were inconsequential details that did not undermine the core narrative of forcible coercion. The Court found her account of being threatened by a 27-year-old man while she was a “frail and young woman” to be credible and consistent with the use of superior force.
The Court also rejected the appellant’s claims regarding the behavior of the victim and the surrounding circumstances—such as her failure to immediately cry for help, the lack of disturbance to animals, and the five-day delay in reporting to her father. These were deemed to be natural reactions of a fearful and traumatized young victim, not indicators of fabrication. The dismissal of the case against Myrna Tadena, who was initially charged as an accomplice, did not render Distor’s story incredible, as the fiscal’s perception was that Myrna was not present during the commission itself. The trial court’s assessment of witness credibility is accorded great weight, and no compelling reason was found to overturn its findings. Thus, the judgment of conviction was upheld.