G.R. No. L-54135. November 21, 1991.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. POLICARPIO RAFANAN, JR., defendant-appellant.

FACTS

The prosecution established that on March 16, 1976, complainant Estelita Ronaya, a 14-year-old househelper, was assisting appellant Policarpio Rafanan, Jr. at his family’s store. As she helped close the store, appellant suddenly pulled her inside, declared his intent to have sexual intercourse, and ignored her refusal and struggle. He threatened her with a bolo pointed at her throat, forced her onto a bamboo bed, and succeeded in having carnal knowledge. Afterward, he threatened to kill her if she reported the incident. Fearful, Estelita remained in the house until the following evening when a family quarrel prompted her return home. She revealed the rape to her mother the next day, March 18, leading to police reporting and appellant’s arrest with the bolo used in the threat.
At trial, appellant pleaded not guilty and was convicted of rape and sentenced to reclusion perpetua. On appeal, he challenged the credibility of the complainant and her mother, citing alleged inconsistencies in their testimonies. He also interposed the defense of insanity, claiming he was suffering from schizophrenia at the time of the incident, supported by expert testimony from a psychiatrist.

ISSUE

The core issues are: (1) whether the alleged inconsistencies in the testimonies of the complainant and her mother impair their credibility; and (2) whether appellant’s insanity defense is sufficiently proven to exempt him from criminal liability.

RULING

The Supreme Court affirmed the conviction. On credibility, the Court ruled that the alleged inconsistencies pertained only to minor details, such as the exact timing of Estelita’s departure from the appellant’s house, and did not relate to the essential elements of the crime. Such minor variances, especially when clarified on cross-examination, do not damage credibility but may even enhance it by negating any suspicion of rehearsed testimony. The complainant’s clear and consistent account of the rape itself, including the use of a bolo to compel submission, remained unshaken.
Regarding the insanity defense, the Court applied the settled doctrine that the accused must prove with clear and convincing evidence that he was completely deprived of intelligence or freedom of will at the exact time of the crime’s commission. The defense psychiatrist’s testimony was deemed insufficient as it described appellant’s general behavioral patterns from a prior confinement and did not specifically relate his mental state to the precise time of the rape. The Court noted that schizophrenia, as described, does not necessarily constitute a complete deprivation of consciousness but may only diminish willpower, which is merely a mitigating circumstance under Article 13(9) of the Revised Penal Code. However, as the prescribed penalty for rape at the time was a single indivisible penalty (reclusion perpetua), no modification of the penalty was warranted. The Court thus upheld the conviction but increased the moral damages awarded.