G.R. No. L-65676 June 24, 1985
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EUFEMIO EGAS alias Dodong, accused-appellant.

FACTS

The prosecution’s evidence established that on June 3, 1978, in Bolangog, Lopez Jaena, Misamis Occidental, the 14-year-old complainant Nazarita Suan was alone in her house. The accused-appellant, Eufemio Egas, who was her third cousin, stealthily entered. He hugged her, dragged her from the kitchen towards the sala, and when she shouted for help, he boxed her in the abdomen, rendering her unconscious. Upon regaining consciousness, she found herself naked, with her vagina bleeding and wet. Appellant, who was still present, threatened to kill her and her parents if she reported the incident. Fearing the threat, she did not immediately disclose the rape. Her pregnancy was later discovered in August 1978, leading to a medical examination confirming a 3-4 month gestation and physical findings consistent with sexual intercourse. A baby boy was subsequently born on February 27, 1979.
The defense presented a contrary version, claiming that he and the complainant were secret sweethearts due to familial opposition and that their sexual relations, which began in December 1977, were consensual. He admitted impregnating her and expressed his intention to marry her. He attributed the rape complaint to a quarrel between their mothers and his failure to apply for a marriage license as planned because he played in a basketball tournament.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that sexual intercourse occurred through force or intimidation and without the consent of the complainant, thereby constituting the crime of rape.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of the young complainant to be credible, straightforward, and consistent on the material points of force, unconsciousness, and lack of consent. Her detailed account of being attacked, boxed into unconsciousness, and later discovering the physical aftermath was deemed natural and convincing. The defense of a sweetheart theory and consensual relations was rejected for being inherently weak and unsupported by credible evidence. The Court noted that such a defense is easily fabricated and, in this case, was belied by the complainant’s immediate and consistent narration of a violent assault. The medical findings of pregnancy and old hymenal lacerations corroborated her claim of prior sexual intercourse. The delay in reporting the crime was satisfactorily explained by the appellant’s grave threats against her and her parents, which instilled reasonable fear in a 14-year-old victim. The trial court’s assessment of witness credibility is accorded great respect, as it is in a better position to observe demeanor. Thus, all elements of rape under Article 335 of the Revised Penal Code were proven beyond reasonable doubt. The appealed decision was affirmed with the modification of increasing the civil indemnity to P20,000.00.