G.R. No. L-58174, July 6, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO DE DIOS y EXCONDE, defendant-appellant.

FACTS

The appellant, Eduardo de Dios, was convicted of rape by the Court of First Instance of Baguio and Benguet and sentenced to reclusion perpetua with damages. The complainant, Concepcion Guanzon, was the appellant’s sweetheart. On March 22, 1973, the appellant visited Guanzon at Makati Medical Center, where her mother was confined. He presented papers purportedly annulling his prior marriage. After a brief visit, he persuaded Guanzon to accompany him to fetch his sister from a nearby college. Instead, he brought her against her will to his house in Baguio City.
At the house, after supper, the appellant dragged Guanzon into a bedroom despite her protests. A prolonged physical struggle ensued, during which Guanzon locked herself in a toilet for about an hour. The appellant eventually broke the lock. The struggle continued until the appellant succeeded in having carnal knowledge of her against her will. She pleaded with him to stop, reminding him they would soon be married, but he persisted. The following morning, she managed to escape and immediately reported the incident, securing a medical examination which confirmed injuries consistent with sexual assault and resistance.

ISSUE

The core issue is whether the prosecution evidence, primarily the complainant’s testimony, 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 meticulously applied the principle that the testimony of a rape victim, if credible, is sufficient to sustain a conviction. It found Guanzon’s narration to be straightforward, detailed, and consistent. Her account of being forcibly taken to Baguio, the protracted struggle inside the bedroom, her temporary refuge in the toilet, and the final consummation of the act against her will was deemed natural and convincing. The medical certificate corroborated her testimony by documenting physical injuries.
The Court rejected the defense’s challenge to her credibility based on their prior romantic relationship and affectionate letters. It ruled that a previous romantic involvement does not negate rape, as consent must be given freely at the time of the sexual act. Her pleas during the struggle demonstrated a clear withholding of consent. The Court also found the testimonies of defense witnesses, who claimed to have seen the couple appearing happy and unharmed, to be inconclusive. These witnesses did not witness the actual crime, and the injuries documented were in areas typically covered by clothing. The appellant’s failure to testify did not bolster the prosecution’s case, as the burden of proof remains with the state. However, the Court held that the prosecution successfully discharged this burden through Guanzon’s positive and credible testimony, corroborated by medical evidence, proving the appellant’s guilt beyond reasonable doubt.