G.R. No. L-75294 December 14, 1987
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROGELIO PARTULAN, defendant-appellant.

FACTS

The accused-appellant, Rogelio Partulan, was convicted by the Court of First Instance of Leyte for the rape of Nonita Dasigan and sentenced to reclusion perpetua. The prosecution evidence established that on June 19, 1982, after the town fiesta, the complainant was walking home when she was accosted by the accused and his companion, Reynaldo Daclitan. The accused dragged her to a grassy area, and despite her resistance and pleas, he threatened her with a small bolo and succeeded in having carnal knowledge. The victim immediately reported the incident to her husband and then to the spouses Enoviso, who accompanied her to the police. A medical examination conducted the following day revealed multiple abrasions on her body.
The appellant assailed his conviction, contending that the trial court erred in giving credence to the complainant’s testimony and in finding his guilt proven beyond reasonable doubt. He alleged inconsistencies in her narrative, argued that the element of force was not established, and posited an alternative theory that the complainant was actually his sweetheart and that the injuries resulted from consensual intimacy or were inflicted by his companion, Reynaldo.

ISSUE

Whether the trial court erred in convicting the accused-appellant of rape based on the credibility of the complainant’s testimony and the sufficiency of the evidence proving force and intimidation.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the complainant’s credibility, finding her to be a plain and sincere witness whose minor testimonial inconsistencies did not detract from the core truth of her account. Her immediate reporting of the crime and the corroborative physical evidence of injuries substantiated her claim. The medical certificate documenting multiple abrasions provided tangible proof of the force employed.
The Court found the appellant’s defenses unworthy of belief. His claim of a prior romantic relationship was unsupported by any corroborative evidence. His alternative explanations for the victim’s injuries and his shifting narratives regarding the sexual act were deemed preposterous and inconsistent. The logic that the victim would not publicly expose an adulterous affair by filing a rape case further undermined his theory. The Court reiterated the doctrine that the trial court’s findings on credibility, especially in rape cases, are accorded great weight. Consequently, all elements of rape—carnal knowledge through force and intimidation—were established beyond reasonable doubt.