G.R. No. L-56699. January 28, 1983. THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PEDRO TAMAYAO alias PETER, defendant-appellant.
FACTS

The appellant, Pedro Tamayao, was convicted of raping his sister-in-law, Victoria Molina. The incident occurred in the early morning of May 9, 1974, at the Nagbannagan public market in Cagayan. Victoria, a market vendor, was sharing a stall with the appellant and his wife (her sister). At around 2:00 a.m., Victoria left the stall to urinate. The appellant followed her, threatened her with a pair of scissors, and forcibly dragged her to a secluded area. Despite her resistance, during which she sustained wounds from the scissors, the appellant succeeded in having carnal knowledge of her. He then threatened to kill her if she reported the incident.
Victoria nevertheless had herself medically examined later that same morning by Dr. Alejandro Acob. The medical certificate documented a stab wound, a cut wound, several scratch wounds, and the presence of semen in her vaginal cavity. Victoria resumed her normal activities that day and only revealed the rape to her husband about two weeks later, after which they reported the crime to the police.

ISSUE

The core issue is whether the prosecution evidence, particularly the testimony of the complainant and the medical findings, is credible and sufficient to prove the appellant’s guilt for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of the complainant credible and consistent. Her immediate medical examination, which objectively corroborated her account of physical struggle and sexual intercourse, was a crucial and decisive factor. The medical findings of wounds and semen were deemed competent and reliable, rejecting the appellant’s technical challenges to the physician’s terminology. The Court also found no credible motive for Victoria to fabricate such a grave charge against her own brother-in-law, a charge that would bring dishonor upon herself and her family. The appellant’s defense, which hinged on the alleged improbability of the crime occurring in a public market area, was insufficient to overcome the positive and corroborated testimony of the victim. The delay in reporting to her husband and the police was satisfactorily explained by the appellant’s threats against her life. Therefore, the evidence established the appellant’s guilt for the crime of rape with the use of a deadly weapon.