GR L 75029; (June, 1987) (Digest)
G.R. No. L-75029. June 30, 1987.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SIEGFRED FAJARDO, accused-appellant.
FACTS
The prosecution’s evidence established that on the evening of August 19, 1982, in Angat, Bulacan, complainant Ma. Charity Lazaro, while walking alone, was accosted by accused-appellant Siegfred Fajardo. He held her arm, professed his love, and upon her rebuke, boxed her in the stomach, rendering her unconscious. She regained consciousness to find herself naked, with Fajardo zippering his shorts before fleeing. She felt pain, found blood oozing from her private part, and discovered her clothing torn and soiled. She immediately reported the rape to her aunt and father, who then reported to the barangay and police. Medical examinations were conducted. Dr. Renato Cruz, a private practitioner, found old hymenal lacerations but no new ones, though he did not discount rape. Due to doubts about Dr. Cruz’s neutrality, the complainant was examined at the NBI, where Dr. Nieto Salvador found fresh, healing hymenal lacerations consistent with trauma inflicted two to three days prior.
The defense presented a contradictory version, claiming that the complainant was his girlfriend and that their encounter involved only a consensual kiss near her gate. He denied the rape allegation entirely, suggesting the complaint arose from a misunderstanding. The defense also questioned minor inconsistencies in the complainant’s testimony regarding the time of the incident and initial conversation.
ISSUE
The core issue is whether the prosecution proved the crime of rape against Siegfred Fajardo beyond reasonable doubt, particularly in light of the conflicting medical findings and the defense of a romantic relationship.
RULING
The Supreme Court affirmed the conviction. The Court found the complainant’s testimony credible, straightforward, and consistent with the physical evidence. The minor inconsistencies cited by the defense regarding the time and initial conversation were deemed trivial and natural for a traumatized victim recalling a harrowing event. The Court gave greater weight to the NBI medico-legal findings over those of the private practitioner. Dr. Salvador, a disinterested expert, documented fresh, healing lacerations corroborating the complainant’s account of recent sexual violation. In contrast, the relationship between Dr. Cruz and the accused cast doubt on his neutrality. The defense’s story was deemed implausible; it was inconceivable that a young woman would fabricate a grave charge of rape, with its attendant social stigma, against a supposed boyfriend without cause. The torn and bloodied clothing provided further corroboration. The Court thus upheld the trial court’s finding of guilt beyond reasonable doubt. However, the moral indemnity was reduced from P50,000 to P20,000, as no special circumstances justified the higher amount. The penalty of reclusion perpetua was sustained.
