Case Summary (G.R. No. 218245)
Facts of the Case
Accused Jesus Empuesto was charged with violating Article 266-A(1)(a) of the RPC for raping AAA on July 3, 2005. The prosecution contended that Empuesto entered AAA’s house stealthily, armed with a bolo, threatened her and her children, and forcibly had carnal knowledge of her without her consent. Testimonies revealed that Empuesto had verified AAA’s husband was out of town before the assault, enhancing the prosecution’s circumstantial evidence.
AAA testified that she recognized Empuesto by sight and voice and described how he subdued her through intimidation and force. Her eight-year-old daughter, BBB, also heard the threats but did not know who the intruder was at the time. Medical examination by Dr. Jaime Gregorio L. Salarda confirmed injuries consistent with sexual assault. AAA promptly reported the incident to her parents-in-law and later to the police.
Defense’s Version
Accused Empuesto claimed an alibi, asserting that he was attending a vigil for a deceased barangay captain at a nearby plaza from the evening of July 2, 2005, until early morning July 3, 2005. His brother Basilio and a cousin named Sanie testified that they accompanied him during this time. Empuesto was arrested around 8:00 a.m. on July 3, 2005, as he was reportedly returning from the vigil.
Trial Court’s Findings
The Regional Trial Court (RTC) assessed the credibility of AAA’s consistent and detailed testimony, including her identification of Empuesto and the corroboration by medical evidence and related testimonies. It found the accused’s alibi weak and physically improbable, considering the proximity between the vigil site and AAA’s house. The RTC convicted Empuesto of rape and sentenced him to reclusion perpetua, awarding civil indemnity of P50,000 to the victim.
Court of Appeals Ruling
The Court of Appeals upheld the RTC’s conviction, emphasizing AAA’s credible and categorical testimony. It rejected the defense’s claims of inconsistency and failure of the victim to resist or shout for help, explaining that threats of violence and the presence of children justified her silence. The CA modified the award of damages by granting P50,000 in moral damages, P30,000 in exemplary damages, and six-percent per annum interest on all damages.
Issue on Appeal
The primary issue on appeal was whether the RTC and CA committed error in finding Empuesto guilty beyond reasonable doubt despite the defense’s alibi and alleged inconsistencies in the victim’s testimony.
Supreme Court's Analysis on Credibility and Burden of Proof
The Supreme Court reiterated that credibility determination is primarily within the purview of trial courts, which have the advantage of observing witnesses’ demeanor. The Court upheld the findings of the RTC and CA, noting that the accused failed to demonstrate any overlooked or misunderstood material fact warranting reversal.
The Court applied established jurisprudential principles in rape cases: (a) accusations can be easily made, making proof challenging but denial more difficult, (b) the victim’s testimony deserves cautious scrutiny, and (c) prosecution evidence must stand on its own merit, independent of the defense’s weaknesses.
Elements of Rape Proven
The Court found all elements of rape under Article 266-A(1)(a) sufficiently proven:
- Carnal knowledge of a woman; and
- The act was performed through force, threat, or intimidation.
AAA positively identified Empuesto as the assailant based on prior acquaintance, voice, and physical presence. The description of the violent intrusion, threats with a bolo, and forced sexual intercourse while immobilized by fear corroborated the non-consensual nature of the act. Minor perceived inconsistencies in AAA’s testimony were deemed immaterial and expected given the traumatic nature of rape.
Victim’s Credibility Upheld
Despite the accused’s arguments, the Court found AAA’s testimony credible, natural, and consistent with human nature and circumstances. The Court emphasized precedent that a rape victim’s testimony, if credible, is sufficient for conviction. AAA’s immediate reporting to relatives and authorities, and the medico-legal findings, reinforced her reliability. The absence of any motive to fabricate the accusation was noted.
Addressing the Alleged Failure to Shout for Help
The accused’s contention that AAA’s failure to resist or cry for help undermined her claim was rejected. The Court recognized the psychological terror imposed by threats of death with a deadly weapon, compelling submission and silence to protect herself and her children.
Weakness of the Alibi Defense
The Court found the alibi defense inherently weak and unsupported by clear, convincing evidence. Discrepancies between Empuesto’s and Basilio’s testimonies, and the admission by Sanie that Empuesto was at the vigil site only part of the time, weakened the claim of conti
...continue reading
Case Syllabus (G.R. No. 218245)
Case Background and Procedural History
- Jesus Empuesto y Socatre ("Accused-Appellant") was charged with rape under Article 266-A(1)(a) of the Revised Penal Code, as amended, for an incident allegedly occurring on July 3, 2005, in Bohol, Philippines.
- The information stated that Accused-Appellant forcibly had carnal knowledge of the victim, AAA, by entering her house stealthily and committing the act against her will, using force, threat, and intimidation.
- Upon arraignment, the accused pleaded not guilty, and the case proceeded to trial.
- The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua, also awarding civil indemnity of P50,000.00 to the victim.
- The Court of Appeals (CA) affirmed the RTC decision with modifications to the damages award, adding moral damages of P50,000.00, exemplary damages of P30,000.00, and imposing interest of 6% per annum on the damages awarded.
- The accused-appellant appealed before the Supreme Court seeking reversal of the decision.
Facts of the Case
- On July 1, 2005, Accused-Appellant invited Rebecca Bantilan (Rebecca) to accompany him to a PTA meeting, since her husband was unavailable; Rebecca is related to the victim’s husband.
- Around 2:30 p.m., accused-appellant was seen peeping through the window of the victim’s house and called out to AAA, calling her "marehan" (a term used because AAA's husband was godfather to accused-appellant’s child).
- On July 3, 2005, at around 1:00 a.m., accused-appellant stealthily entered AAA’s house through a hole in the bamboo floor.
- The house was elevated with a GI roof and bamboo slats; AAA and her four children were sleeping inside a mosquito net in a lit room.
- Accused-appellant was armed with a bolo; he switched off the light, threatened to kill AAA and her children if she made noise, and demanded only the victim.
- The accused forced AAA to remove her panties and forcibly inserted his penis into her vagina while she was breastfeeding her youngest child.
- BBB, the eight-year-old daughter, overheard the threats but did not act out of fear.
- After the assault, accused-appellant left through the hole in the floor; AAA and BBB discovered the hole and items left behind such as a black female panty and a bolo belonging to the victim’s family.
- The victim reported the incident to her parents-in-law and subsequently to the police, submitting to a medico-legal examination by Dr. Jaime Gregorio L. Salarda.
- The medical report confirmed physical findings consistent with rape.
Prosecution’s Evidence and Testimony
- AAA gave consistent, straightforward, and credible testimony identifying accused-appellant as the intruder and perpetrator.
- Rebecca’s testimony showed accused-appellant’s knowledge that the victim’s husband was not around, indicating premeditation.
- Dr. Salarda’s medico-legal examination corroborated AAA’s account by documenting fresh lacerations and ulcerations consistent with sexual assault.
- The victim’s prompt reporting and submission to medic