G.R. No. L-68992 September 26, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FAUSTINO PACNIS, accused-appellant.

FACTS

The prosecution’s evidence established that on February 18, 1981, sixteen-year-old Fe Guillermo was fetched from school by Linda Lumabas, a family friend. Lumabas invited Guillermo to the house of appellant Faustino Pacnis. After lunch, Pacnis and Lumabas suddenly grabbed Guillermo, forcibly dragged her to a bedroom, and locked her inside with Pacnis. Guillermo resisted Pacnis’s advances. Exasperated, Pacnis struck her multiple times with a piece of wood, causing her to lose consciousness. Upon regaining consciousness, she found herself without underwear, with vaginal bleeding and pain, and Pacnis seated beside her telling her to go home. She immediately reported the incident. A medical examination revealed contusions on her forearms and thighs and a laceration on her hymen, consistent with forced sexual intercourse.
The defense presented a contradictory account, claiming Guillermo and Pacnis were sweethearts and any sexual act was consensual. Pacnis testified that Guillermo had come to his house that morning showing injuries allegedly inflicted by her father. He asserted the rape charge was fabricated due to a later quarrel.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Faustino Pacnis committed rape through force and intimidation.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the complainant’s credibility, which is accorded great weight. The legal logic centered on the inherent improbability that a young woman of decent repute would publicly accuse a man of a crime as serious as rape, subject herself to physical examination and trial, and endure social stigma, unless motivated by a truthful desire for justice. The medical findings of contusions and a hymenal laceration objectively corroborated her testimony of a violent struggle and sexual assault. The defense of a romantic relationship was deemed unconvincing and unsupported by evidence, failing to provide a credible motive for Guillermo to fabricate the charge. The Court also noted that the flight of co-accused Linda Lumabas, who remained at large, undermined the defense’s claim of her innocence. The penalty of reclusion perpetua was sustained. The Court modified the decision by increasing the indemnity awarded to the victim from P10,000 to P20,000.