Primordial consideration in rape cases

A rape charge is a serious matter with pernicious consequences both for the appellant and the complainant; hence, utmost care must be taken in the review of a decision involving conviction of rape. Thus, in the disposition and review of rape cases, the Court is guided by certain principles. First, the prosecution has to show the guilt of the accused by proof beyond reasonable doubt or that degree of proof that, to an unprejudiced mind, produces conviction. Second, the evidence for the prosecution must stand or fall on its own merits and cannot draw strength from the weakness of the evidence of the defense. Third, unless there are special reasons, the findings of trial courts, especially regarding the credibility of witnesses, are entitled to great respect and will not be disturbed on appeal. Fourth, an accusation for rape can be made with facility; it is difficult to prove but more difficult for the person accused, though innocent, to disprove. And fifth, in view of the intrinsic nature of the crime of rape, in which only two persons are usually involved, the testimony of the complainant must be scrutinized with extreme caution.

It is well-settled that the appellant may be convicted of rape based solely on the testimony of the victim, as long as the same is competent and credible. This is primarily because the crime of rape is usually committed in a private place where only the aggressor and the rape victim are present. Moreover, even the trial court mentioned in its Decision that even in the absence of the corroborative testimonies of the prosecutions other witnesses, the testimony of AAA can stand on its ground and is enough to convict the appellant.

Accordingly, the primordial consideration in a determination concerning the crime of rape is the credibility of complainants testimony. Time and again, the Supreme Court has held that when it comes to the issue of credibility of the victim or the prosecution witnesses, the findings of the trial courts carry great weight and respect and, generally, the appellate courts will not overturn the said findings unless the trial court overlooked, misunderstood or misapplied some facts or circumstances of weight and substance which will alter the assailed decision or affect the result of the case. This is so because trial courts are in the best position to ascertain and measure the sincerity and spontaneity of witnesses through their actual observation of the witnesses manner of testifying, their demeanor and behavior in court. Trial judges enjoy the advantage of observing the witness deportment and manner of testifying, her furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath -- all of which are useful aids for an accurate determination of a witness honesty and sincerity. Trial judges, therefore, can better determine if such witnesses are telling the truth, being in the ideal position to weigh conflicting testimonies. Again, unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected, for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they were lying. The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.

The Supreme Court, upon examining the records of the present case, fully agrees in the findings of both the trial court and the appellate court that the testimony of AAA is credible and enough to convict the appellant even without the corroborating testimonies of the other prosecution witnesses. Her testimony on how she was raped by the appellant on 24 June 1997 was characterized by the trial court and affirmed by the Court of Appeals as clear, straightforward and bereft of any material or significant inconsistencies. Further, the Supreme court notes that while testifying, AAA broke down in tears. The crying of a victim during her testimony is eloquent evidence of the credibility of the rape charge with the verity borne out of human nature and experience. Similarly, no woman, least of all a child, would concoct a story of defloration, allow an examination of her private parts and subject herself to public trial or ridicule if she has not, in truth, been a victim of rape and impelled to seek justice for the wrong done to her. It is also highly inconceivable for a girl to provide details of a rape and ascribe such wickedness to her stepfather just because she resents being disciplined by him since, by thus charging him, she would also expose herself to extreme humiliation, even stigma. Testimonies of child-victims are normally given full weight and credit, since when a woman, more so if she is a minor, says that she has been raped, she says in effect all that is necessary to show that rape was committed. Youth and immaturity could indeed be badges of truth. This observation is a matter of judicial cognizance borne out by human nature and experience. There could not have been a more powerful testament to the truth than this public baring of unspoken grief. More so, it is an accepted doctrine that in the absence of evidence of improper motive on the part of the victim to falsely testify against the accused, her testimony deserves credence. And in this case, it was never shown that the complainant had an ill motive in filing a case against the appellant other than seeking justice for what had happened to her. (G.R. No. 177749; December 17, 2007)