3 Precepts in Rape Cases: Accusation, Extreme Scrutiny & Victim's Credibility
In essence, accused-appellants defense consists of denial and alibi, and of casting doubt on AAAs credibility.
It has been ruled that in the review of rape cases, courts are guided by the following precepts: (a) an accusation of rape can be made with facility, but more difficult for the accused, though innocent, to disprove it; (b) the complainant's testimony must be scrutinized with extreme caution since, by the very nature of the crime, only two (2) persons are normally involved; and (c) if the complainant's testimony is convincingly credible, the accused may be convicted of the crime.
In prosecuting for rape, the single most important issue is the complainant's credibility. A medical examination and a medical certificate are merely corroborative and are not indispensable to a prosecution for rape. The court may convict the accused based solely on the victims credible, natural, and convincing testimony. In rape cases, the lone testimony of the victim, if credible and free from fatal and material inconsistencies and contradictions, can be the basis for the prosecution and conviction of the accused.The rule can no less be true than when a rape victim testifies against her own father; unquestionably, there would be reason to give it greater weight than usual.
In any event, matters affecting credibility are best left to the trial court with its peculiar opportunity to observe the deportment of a witness on the stand as against the reliance by an appellate court on the mute pages of the records of the case. The spontaneity with which the victim has detailed the incidence of rape, the tears she has shed at the stand while recounting her experience, and her consistency almost throughout her account dispel any insinuation of a rehearsed testimony. The eloquent testimony of the victim, coupled with the medical findings attesting to her non-virgin state, should be enough to confirm the truth of the charges. (G.R. No. 172368; December 27, 2007)
