GR L 62712; (March, 1991) (Digest)
G.R. No. L-62712; March 11, 1991
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROGER FELICIANO, defendant-appellant.
FACTS
The accused, Roger Feliciano, was convicted of rape by the Court of First Instance of Bulacan and sentenced to reclusion perpetua. The information alleged that on September 19, 1975, in Norzagaray, Bulacan, he rendered the complainant, Leoncia Villarama, unconscious by hitting her stomach and then had carnal knowledge of her against her will. The complainant testified that she was asleep in her uncle’s tailor shop when she was awakened by the accused lying on top of her. When she shouted, he covered her mouth, struck her stomach, and she lost consciousness. Upon regaining consciousness, she felt vaginal pain, found her panty pulled down, and discovered a sticky substance, later identified as blood, on her vagina. The accused, who was her uncle by affinity, warned her not to report the incident, threatening to kill her if she told his wife.
The defense, on appeal, assigned errors focusing on the prosecution’s alleged failure to prove the elements of carnal knowledge and force or intimidation beyond reasonable doubt, and the complainant’s unexplained delay in reporting the crime.
ISSUE
Whether the prosecution successfully established the guilt of the accused for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction, modifying only the amount of moral damages. The Court held that all elements of rape were proven. The medico-legal report, which found a healing hymenal laceration compatible with recent sexual intercourse, corroborated the complainant’s testimony of carnal knowledge. The force and intimidation were established by the complainant’s account of being struck, rendered unconscious, and subsequently threatened with death if she reported the incident. The Court emphasized that the accused’s act of lying on top of the complainant, a position he had no right to be in, coupled with the blow, constituted the requisite force.
Regarding the delay in reporting, the Court found it sufficiently explained by the accused’s moral ascendancy as an uncle-employer and his explicit threats. The complainant’s initial silence and subsequent disclosure to relatives in Manila were consistent with the fear instilled by the accused. The Court reiterated that delay alone does not undermine credibility, especially when the victim is cowed by threats. Thus, the guilt of the accused was established beyond reasonable doubt.