Case Summary (G.R. No. 92442-43)
Allegations
The two complaints filed on July 26, 1989, allege that Dela Cruz, using a knife for intimidation, sexually assaulted Centeno on the specified dates, against her will and without her consent.
Trial Proceedings
Upon arraignment, Dela Cruz entered a plea of not guilty. The prosecution's version of events was presented through the testimony of the complainant, detailing the incidents of alleged rape, the threats made by Dela Cruz, and the coercive circumstances surrounding both incidents.
Testimonies of the Complainant
Centeno described how Dela Cruz lured her under false pretenses to Mang Romy's house, threatened her with a knife, forced her into submission, and sexually assaulted her. She testified about the fear induced by the threats, which prevented her from reporting the incidents to her parents immediately.
Dela Cruz’s Defense
The accused denied the allegations, asserting no sexual intercourse occurred. He claimed that the locations mentioned were public and had no walls, making it impossible for an assault to go unnoticed. His defense included testimonies from his wife and acquaintances corroborating his claims of being at home with karate students during the incidents.
Trial Court Decisions
The Regional Trial Court found Dela Cruz guilty of both counts of rape, sentencing him to double reclusion perpetua and ordering him to pay damages to the victim. The court relied heavily on the complainant’s testimony, determining it was credible despite the defense’s efforts to challenge it.
Appeal
Dela Cruz appealed the verdict, contending that the trial court erred in finding sufficient evidence to support his conviction. He argued the prosecution's evidence was not credible, asserting inconsistencies in the complainant's testimony and questioning the circumstances under which the incidents allegedly occurred.
Credibility of the Complainant
The appellate court considered three critical principles relevant to the assessment of rape cases, particularly emphasizing the need for careful scrutiny of the complainant's testimony due to the intrinsic nature of the crime. The court largely reflected on the trial judge's conclusion that the complainant appeared honest and straightforward during her testimony.
Scrutiny of Evidence
On reviewing the evidence, the appellate court noted discrepancies that raised reasonable doubts regarding the complainant’s claims. Key points included:
- Lack of Immediate Disclosure: The complainant did not report the incidents until much later and only after discussing the matter with friends.
- Inconsistencies in Testimonies: There were contradictions between the complainant's courtroom testimony and her previous statements, which indicated a lack of reliability.
- Opportunity to Escape: There were opportunities for the complainant to resist or call for help during the incidents but she did not do so, raising doubts about the al
Case Syllabus (G.R. No. 92442-43)
Case Information
- Case Reference: G.R. No. 92442-43
- Decided On: March 23, 1992
- Division: First Division
- Decision by: Justice Medialdea
Factual Background
- Accusation: Nestor dela Cruz was charged with two counts of rape against Remedios Centeno y Lagrosa, a 15-year-old girl.
- Incident Dates:
- First Incident: June 20, 1988
- Second Incident: May 8, 1989
- Location: Both incidents allegedly occurred in Kalookan City, Metro Manila.
Allegations
First Count (Criminal Case No. C-33236):
- The complainant visited Nestor dela Cruz to inquire about a karate tournament.
- She was invited to the house of a certain Mang Romy, where she was threatened with a knife, forced to lie down, and raped.
Second Count (Criminal Case No. C-33237):
- The complainant was again threatened with a knife when she went to Nestor's house for a denture fitting.
- She was similarly assaulted and raped.
Proceedings and Testimonies
Prosecution's Account:
- The complainant testified about both incidents in detail, describing the threats and actions of the accused during the alleged rapes.
- She indicated that fear of death prevented her from reporting the incidents to her parents.
Defense's Account:
- Nestor dela Cruz denied the allegations, asserting that the locations where the rapes allegedly occurred were public and visible.
- He provided alibi witnesses, including his wife and karate students, who corroborated his claims of being in th