GR L 63265; (March, 1984) (Digest)
G.R. No. 63265 . March 13, 1984.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JOSE MARZAN alias CARLING, Defendant-Appellant.
FACTS
The prosecution established that on January 26, 1978, in Urdaneta, Pangasinan, the accused, Jose Marzan, went to the store of Saturnina Esteves, a 30-year-old widow. He told her his wife had won in jueteng and would pay their store debt, requesting Saturnina to come to his house to collect. Upon arrival, Marzan opened the door, claimed his wife was inside, and led Saturnina upstairs. He then pointed a balisong at her neck, boxed her, and struck her thighs with the weapon’s handle, causing her to lose consciousness. She awoke to find Marzan having sexual intercourse with her. Threatened with death if she reported the incident, she later went home and eventually reported the rape to her family and authorities. A medical examination confirmed old contusions on her neck, breasts, and thigh.
The defense presented aๆช็ถไธๅ็ narrative, claiming the sexual intercourse was consensual and part of an ongoing illicit affair that began months prior. Appellant alleged that Saturninaโs injuries were inflicted by her brother, Marcial, upon discovering the affair, and that her accusation was fabricated. He argued that Saturnina, being a 30-year-old widow who had traveled abroad, was not an “unsuspecting provinciana” who could be easily duped.
ISSUE
The core issue is one of credibility: whether the sexual intercourse on January 26, 1978, was accomplished through force and intimidation (rape) or was a voluntary act between consenting adults.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s findings, emphasizing that the assessment of witness credibility is best left to the trial judge who observed their demeanor firsthand. The prosecution’s evidence was deemed clear and convincing. Saturninaโs detailed account of being lured, threatened with a weapon, assaulted, and raped was consistent and credible. The medical certificate corroborated her testimony of physical violence. The Court found the defense’s theory of a consensual affair and subsequent fabrication to be implausible and loosely woven. The claim that her brother inflicted the injuries was deemed incredible and inconsistent with the brother’s demonstrated concern. Saturninaโs age and travel experience did not negate the fact that she was tricked and forcibly assaulted. The defense failed to prove that the trial court overlooked any substantial fact that would alter the case’s outcome. Thus, the guilt of the accused for the crime of rape was proven beyond reasonable doubt.