G.R. Nos. 70565-67 November 9, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROBERT POCULAN, accused-appellant.

FACTS

Accused-appellant Robert Poculan, the Municipal Mayor of Rizal, Zamboanga del Norte, was charged with three counts of rape against his clerk, Conchita Rone, allegedly committed on the evening of March 22, 1980, and at dawn the following day. The prosecution evidence established that on March 22, 1980, appellant summoned Rone to his house under the pretext of official work. After she finished, he offered her a ride home. Instead, the motorcab, with only the driver, appellant, and Rone as passengers, proceeded to a remote area. Appellant forcibly brought Rone to a hut, threatened her with a pistol, and raped her twice that evening. He then took her to another house, where he raped her a third time in the early morning of March 23 before finally allowing her to leave.
The defense presented a denial and alibi, claiming the sexual acts were consensual and that Rone had motives to fabricate the charges due to political instigation. Several defense witnesses retracted earlier sworn statements supporting the prosecution. The trial court convicted Poculan on all three counts, sentencing him to three penalties of reclusion perpetua and ordering him to pay damages.

ISSUE

Whether the guilt of the accused-appellant for three counts of rape was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, emphasizing that such findings are generally accorded the highest respect. The Court found Rone’s testimony to be credible, consistent, and sufficient to establish the elements of rape. Her detailed account of how appellant, exploiting his moral ascendancy and official power as mayor, used force, intimidation, and a firearm to sexually assault her on three separate occasions was deemed convincing and met the requisite test of credibility.
The Court rejected the defense of consensuality and alibi as inherently weak and unsubstantiated. It noted the unnaturalness of the defense witnesses’ declarations and the appellant’s demonstrated influence over them, as well as his efforts to quash the charges through political appeals. The aggravating circumstance of abuse of public position was properly appreciated, as appellant used his official authority to summon the victim under a false pretext, facilitating the commission of the crime. The prosecution evidence, standing firmly on its own, proved appellant’s guilt beyond reasonable doubt for three distinct acts of rape.