G.R. No. 254194 - Rosita vs. Zamora

The accused-appellant Romeo A. Corrales was charged with the crime of rape based on the complaint filed by the victim, Milagros Miranda.
The allegation stated that on or about December 29, 1983, in Caloocan City, Metro Manila, Corrales, with lewd designs, employed force and intimidation to compel Milagros Miranda into a non-consensual sexual act.
The complaint detailed that the accused used a pointed instrument to threaten the victim, warning her not to shout by asserting that he would kill her if she resisted.
Additional elements in the charge noted that the victim, who was seven months pregnant, was forced to remove her clothes and was ultimately subjected to an act of sexual intercourse, despite her attempts to resist due to fear for her life.

The victim testified that she was awakened from sleep at her residence at 126 Pangako St., Bagong Barrio, Caloocan City, by the presence of Corrales.
During the assault, the victim repeatedly confirmed that any resistance was nullified by the threat of death as reiterated in her testimonies. For instance:

When asked about her inability to shout or resist, she testified that the accused had threatened to kill her.
Despite being instructed to remove her clothes and remain naked, her state of fear and shock prevented her from undertaking any physical resistance.

After initial sexual contact where the accused masturbated, he later inserted his penis into the victim’s vagina.
The victim was coerced by continuous threats not to seek immediate police intervention, as the assailant warned her of fatal consequences.

Based on the victim’s complaint, law enforcement conducted an investigation which led to the apprehension of Romeo Corrales on January 4, 1985.
The trial court, after hearing testimonies and evaluating the presented evidence, convicted Corrales of rape beyond reasonable doubt.
In its decision, the trial court sentenced the accused to Reclusion Perpetua and ordered him to indemnify the victim with the sum of P30,000.00.

The accused, while pleading not guilty, raised two primary assignments of error:

The trial court erred in holding that there was use of force and intimidation in carrying out the rape.
The trial court erred in finding him guilty beyond reasonable doubt.

There was no necessity for force since the lack of physical injury, compounded by a prior relationship of “bad blood” between the families, could have influenced the complaint.
The delay in reporting the incident raised a possibility of doubt regarding the credibility of the evidence, citing that the accused was asleep at his mother-in-law’s house at the time of the alleged crime.

The use of force and intimidation was evident from the victim’s repeated statements about the threat to her life.
Minor inconsistencies in the testimony and the brief delay in reporting were attributable to the shock and fear experienced by the victim following the assault.

Whether the trial court erred in concluding that force and intimidation were used during the commission of the rape, despite assertions of no physical injury and the absence of overt physical resistance.

Does the absence of substantial physical injury negate the use of force, given that intimidation affects the victim’s mind?
Was the victim’s lack of resistance sufficiently explained by the employed threats and her vulnerable condition (being seven months pregnant)?

Whether the trial court erred in convicting the accused beyond reasonable doubt, considering the alleged delays in reporting and the defense's contention of pre-existing familial “bad blood.”

Can minor inconsistencies in the victim’s account, as well as the delay in reporting due to fear, be deemed significant enough to undermine her testimony?
Is the accused’s alibi, which places him at his mother-in-law’s residence during the time of the assault, supported by sufficient corroborative evidence?

Whether the established facts and testimonial corroboration were adequate to sustain a conviction on the sole basis of the victim’s testimony.

Should the trial evidence relying on the victim’s identification and recounting of events prevail over the defense’s explanations related to motive and alibi?