G.R. No. L-62387 June 19, 1985
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AVELINO REYES, accused-appellant.

FACTS

The accused-appellant, Avelino Reyes, was convicted of rape by the Court of First Instance of Northern Samar and sentenced to reclusion perpetua. The prosecution established that on the night of August 10, 1979, Reyes, who had been drinking, sexually assaulted his 16-year-old maid, Vicky Dalangpan, in his own home. The victim testified that she was sleeping on a rattan bed in the sala when Reyes, having removed his pants, got on top of her, threatened her with a knife to prevent her from shouting, and forcibly had carnal knowledge against her will. She struggled and shouted, but the accused’s wife, sleeping nearby separated by a curtain, did not awaken. After the act, the victim cried and immediately reported the assault to the wife, leading to a marital quarrel. She later escaped the house and reported the rape to the Barangay Captain.
The defense presented a different narrative. Reyes claimed he arrived home drunk and slept on the rattan bed, which was the maid’s usual sleeping place. He alleged he was awakened by his wife, who discovered the maid sleeping beside him, and that the complaint was a fabrication instigated by his wife due to marital discord. He argued that the immediate reporting to his wife and the barangay captain was inconsistent with the behavior of a true victim, suggesting the story was concocted.

ISSUE

The core issue is whether the prosecution evidence, particularly the testimony of the complainant, was credible and sufficient to prove the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction, finding the victim’s testimony credible and consistent. The Court emphasized that in rape cases, the accused may be convicted solely on the credible testimony of the victim. The Court found no ill motive for the young, unmarried complainant to fabricate a charge that would expose her to public shame and humiliation. Her immediate outcry to the accused’s wife and her prompt escape to report the crime to authorities were deemed natural reactions consistent with a genuine victim’s behavior.
The Court rejected the defense’s theory of fabrication, noting that the accused’s wife, who allegedly instigated the complaint, never testified to support this claim. Furthermore, the medical certificate showing contusions and abrasions on the victim corroborated her account of a struggle and the use of force. The Court also found the defense’s alternative scenario—that the wife would use a false rape charge as leverage in a quarrel—to be unconvincing and contrary to human experience. The award of civil indemnity was increased from P12,000 to P30,000 in line with prevailing jurisprudence. The judgment of conviction was thus affirmed with modification.