G.R. No. L-72354. June 30, 1987.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO PEÑA, JR., accused-appellant.

FACTS

The accused-appellant, Antonio Peña Jr., was convicted by the trial court of the crime of rape. The prosecution evidence established that in the early morning of April 15, 1984, inside the Ellen’s Folk House in Cotabato City, the 18-year-old complainant, Nancy Tejas, was attacked. As she left her room to urinate, Peña suddenly covered her mouth, pressed a bladed weapon to her neck, and threatened to kill her and her family. He then dragged her to the main door, pushed her down, and, while continuously threatening her with the weapon, forcibly removed her clothing and had carnal knowledge against her will. After the act, the victim retreated to her room in distress. She later reported the incident to her fiancé, Romeo Angeles.
The defense, through Peña’s testimony and that of other witnesses, essentially denied the accusation. On appeal, Peña questioned the credibility of the complainant, arguing that the circumstances made her story implausible. He contended that it was improbable he would know she would exit her room, that she did not seek help from nearby sleeping employees, and that the sexual act could have been completed so quickly without her cooperation, suggesting consent instead of forcible rape.

ISSUE

Whether the trial court gravely erred in convicting the accused-appellant of rape beyond reasonable doubt based on the complainant’s testimony.

RULING

The Supreme Court affirmed the conviction, upholding the trial court’s assessment of the complainant’s credibility. The Court meticulously addressed each of the appellant’s arguments. First, the appellant’s presence was not coincidental; the evidence showed he was a former employee familiar with the victim’s routines and had been drinking in the establishment that night, providing him the opportunity to lie in wait. Second, the victim’s failure to scream for help was rationally explained by the immediate and overwhelming threat of the deadly weapon pressed against her neck, which instilled paralyzing fear. The Court emphasized that consent vitiated by fear of immediate and serious bodily harm is not consent at all.
Finally, the Court found no merit in the argument regarding the brevity of the act, stating that the duration of sexual intercourse is irrelevant to the determination of force and lack of consent. The victim’s conduct after the incident—her immediate distress, her report to a trusted confidant, and her eventual decision to file a formal complaint despite the fear of public humiliation—was consistent with that of an innocent victim. The Court found her testimony to be clear, credible, and consistent on material points, sufficient to establish the elements of rape. The appealed decision was affirmed with the modification deleting the order for subsidiary imprisonment.