G.R. No. L-75293 August 17, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOAQUINITO HACBANG, accused-appellant.

FACTS

The case originated from a complaint filed by Fe Mercado, who accused Joaquinito Hacbang of rape. The prosecution’s evidence established that in the early morning of January 16, 1980, in Tacloban City, the appellant approached Mercado as she waited for transportation outside a hospital. He poked a knife at her neck, threatened to kill her if she shouted, and forcibly led her to a skating rink near the city hall. There, amidst tall ipil-ipil trees, he removed her clothes and his own, and despite her resistance, succeeded in having carnal knowledge with her while continuing to threaten her with the knife. After the act, Mercado managed to board a vehicle home, reported the incident to her father, and underwent a medical examination which revealed findings consistent with recent sexual intercourse and physical trauma.
The defense presented a starkly different version. Appellant Hacbang claimed that he and Mercado were sweethearts and that their sexual encounter on that date was consensual. He testified that they had been introduced by a common friend and had been in a relationship for some time. To support this claim, he presented his father and their household helper as witnesses. The trial court, however, found the prosecution’s evidence credible and convicted Hacbang of rape, sentencing him to reclusion perpetua.

ISSUE

The core issue for resolution is whether the prosecution proved beyond reasonable doubt that the accused-appellant committed rape through force and intimidation, thereby rendering the defense of a consensual relationship between the parties untenable.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the credibility of the complainant’s testimony and the inherent improbability of the defense. The Court emphasized the well-settled doctrine that the testimony of a rape victim, if credible, is sufficient to sustain a conviction. Mercado’s detailed account of the threat with a knife, the forcible abduction to a secluded area, and the subsequent sexual assault was found to be clear, consistent, and credible. Her immediate reporting of the crime, the corroborative medical findings, and her subsequent identification and retrieval of her watch from the appellant bolstered her testimony.
The Court systematically rejected the appellant’s defense of a sweetheart relationship. It noted the absence of any substantial corroborative evidence for such a claim, such as love letters, photographs, or the testimony of the alleged common friend who introduced them. The fact that the appellant and his own father displayed a lack of basic knowledge about Mercado’s family background further undermined the defense. The Court reasoned that no young Filipina would willingly undergo the humiliation of a public rape trial unless motivated by a sincere desire to seek justice for a wrong committed against her. The appellant’s failure to flee was deemed not indicative of innocence, and the victim’s conduct during the ordeal was found to be consistent with the natural fear induced by a lethal threat. Consequently, the trial court’s factual findings and conclusion of guilt beyond reasonable doubt were upheld.