Facts:

• Ernesto Atuel, also known as Loloy Bolhog, was charged with rape under Article 335 of the Revised Penal Code.
• The complaint was filed on August 28, 1991, by the mother of the complainant, Felicitas Sayon, who was identified as a mental patient.
• The alleged incident occurred on August 23, 1991, in Davao City, Philippines.
• Atuel was accused of using force and intimidation to have carnal knowledge of Felicitas against her will.
• He was arraigned on September 13, 1991, and pleaded not guilty.
• On March 29, 1992, the Regional Trial Court of Davao City found him guilty of rape and sentenced him to reclusion perpetua, along with a P40,000 indemnity to the complainant.
• The prosecution's case included testimony from Severo "Berot" Echavez, a neighbor who witnessed the incident, and Police Officer Prospero Ondong, who corroborated Echavez's account.
• The defense presented witnesses claiming another individual, Caloy Reynoso, was responsible and argued that the prosecution's evidence was insufficient.

Issue:

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Ruling:

• The Supreme Court ruled that the trial court did not err in finding the testimonies of the prosecution witnesses credible and sufficient for conviction.
• The Court affirmed the trial court's decision, concluding tha...(Unlock)

Ratio:

• The Supreme Court emphasized the importance of witness credibility in rape cases.
• Minor inconsistencies in the testimonies of prosecution witnesses do not undermine their credibility, especially given the traumatic nature of the crime.
• Felicitas Sayon's mental illness affected her ability to recall details but did not negate her status as a victim of rape.
• Severo Echavez's straightforward and credible testimony was corroborated by Officer Ondong, who apprehended Atuel during the crime.
• The defense's a...continue reading