In People v. Amante, the Supreme Court affirmed the conviction of Angel Amante for two counts of rape, emphasizing the credibility of the victim’s testimony and the impact of intimidation. The court underscored that a rape victim’s testimony, if credible, is sufficient for conviction, even without corroborating evidence. This decision highlights the importance of considering the psychological impact of rape, including delayed reporting due to fear and intimidation. The accused was sentenced to reclusion perpetua for each count and ordered to pay moral damages and civil indemnity, reinforcing the gravity of the crime and the protection afforded to victims under Philippine law.

Silenced by Fear: When a Grandniece’s Trust Is Violated

The case revolves around Angel Amante, who was accused of raping his common-law wife’s grandniece, Evelyn Ocinar, on two separate occasions. Evelyn stayed in Angel’s house while looking for work in Manila. The incidents allegedly occurred on December 28, 1996, and February 15, 1997. The central question before the court was whether the prosecution successfully proved Angel Amante’s guilt beyond a reasonable doubt, relying heavily on the testimony of the complainant.

Evelyn testified that on both occasions, Angel entered her room at night, threatened her with a knife, and forcibly had sexual intercourse with her. She stated that she did not immediately report the incidents due to fear of the accused, who repeatedly threatened her. Evelyn eventually confided in her maternal grandaunt, Luzanta Barquin, who then reported the incidents to the barangay authorities.

The prosecution presented Evelyn’s testimony and the medico-legal report, which confirmed her pregnancy. The defense, however, argued that the charges were fabricated due to a feud between Angel and Luzanta over a roof gutter. Angel claimed he was with his common-law wife and other relatives during the alleged incidents. The trial court found Angel guilty, giving more weight to the prosecution’s evidence. On appeal, the Supreme Court was tasked with evaluating the credibility of the witnesses and the sufficiency of the evidence presented.

The Supreme Court based its decision on established principles in rape cases. Citing People v. Quintal, 125 SCRA 734 (1983), the court recognized that rape accusations are easily made but difficult to disprove. Therefore, the complainant’s testimony must be scrutinized with utmost caution. However, the court also emphasized that the sole testimony of the rape victim is sufficient for conviction if found credible, as stated in People v. Rivera, G.R. No. 139180, July 31, 2001. The court found Evelyn’s testimony to be direct, unwavering, and consistent, reinforcing its credibility.

Q Di ba nagreklamo ka ng dalawang beses na panggagahasa na diumano ginawa ng akusado na si Angel Amante. Isa noong December 28, 1996 at noong February 15, 1997?

A Opo.

The court acknowledged the victim’s fear and intimidation, which led to the delay in reporting the crime. The delay was deemed reasonable under the circumstances, as the accused had repeatedly threatened the victim with harm if she disclosed the incidents. The court also noted that the defense’s claim of a fabricated charge due to a feud over a roof gutter was untenable. It was improbable that a young woman would file a non-bailable offense of rape merely because of a minor property dispute. The court also found no improper motive for Evelyn to falsely testify against Angel.

The defense presented alibi and denial, which the court deemed weak and self-serving. The testimonies of Angel’s common-law wife and her daughter were found biased and inconsistent. The court emphasized that between the positive declarations of the prosecution witness and the negative statements of the accused, the former deserves more credence, citing People v. Fraga, 330 SCRA 699 (2000).

Furthermore, the court noted that Angel attempted to reach a settlement with Evelyn, indicating a consciousness of guilt. His subsequent flight from the authorities further supported this conclusion. It is important to note the elements of rape, which include carnal knowledge of the complainant without her consent and the employment of force and intimidation. In this case, the use of a knife to threaten the victim satisfied the element of force and intimidation, even if the knife itself was not presented in court, as cited in People v. Maglente, 306 SCRA 546 (1999).

Building on this principle, the court addressed the medico-legal report, which confirmed Evelyn’s pregnancy. Although the trial court did not conclusively establish Angel as the father, the Supreme Court noted that Evelyn gave birth within a normal gestation period from the date of the first rape. The court invoked the presumption that the child was begotten as a result of the rape, unless the accused could prove physical impossibility or sexual intercourse with another man. Since Angel failed to provide such evidence, the court ordered him to pay support for the child, the amount to be determined by the trial court.

This approach contrasts with cases where the pregnancy could not be definitively linked to the rape. However, the court clarified that Angel could not be compelled to acknowledge the child because he claimed to be married, and the prosecution did not present evidence to the contrary. Therefore, his civil status prevented him from legally recognizing the child. However, considering the crime and its impact, the court upheld the award of moral damages and civil indemnity to the victim. Moral damages are awarded in rape cases without further proof of injury, and civil indemnity is mandatory upon the finding of rape, as stated in People v. Catubig, G.R. No. 137842, Aug. 23, 2001.

In summary, the Supreme Court affirmed the conviction of Angel Amante, underscoring the weight given to the victim’s testimony, the reasonableness of the delay in reporting, and the implications of the medico-legal evidence. The court’s decision reinforced the protective measures afforded to rape victims under Philippine law. This case provides significant guidance on how courts should evaluate evidence and address the psychological impact of rape on victims.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution presented sufficient evidence to prove beyond a reasonable doubt that Angel Amante committed the crime of rape against Evelyn Ocinar. The Supreme Court focused on the credibility of the victim’s testimony and the evidence of force and intimidation.
Why did the victim delay reporting the rape incidents?	Evelyn Ocinar delayed reporting the incidents due to fear and intimidation by Angel Amante, who repeatedly threatened her with harm if she disclosed the rapes to anyone. The court considered this a valid reason for the delay, given the circumstances.
Was the victim’s testimony enough to convict the accused?	Yes, the Supreme Court affirmed that the lone testimony of a rape victim is sufficient to warrant a judgment of conviction if the testimony is found credible. The court deemed Evelyn Ocinar’s testimony to be direct, unequivocal, and consistent, thus credible.
What was the accused’s defense?	Angel Amante claimed that the charges were fabricated due to a feud over a roof gutter between him and the victim’s grandaunt. He also presented an alibi, stating that he was with his common-law wife and other relatives during the alleged incidents.
How did the court view the accused’s defense?	The court found the accused’s defense to be weak and self-serving. The alibi was not credible, and the claim of a fabricated charge over a minor property dispute was considered absurd.
What was the significance of the medico-legal report?	The medico-legal report confirmed that Evelyn Ocinar was pregnant. Given the timing of the rapes, the court presumed that the child was conceived as a result of the rape, and ordered Angel Amante to provide support for the child.
What is the penalty for rape under Philippine law?	At the time of the offense, rape under Article 335 of the Revised Penal Code, as amended by R.A. No. 7659, was punishable by reclusion perpetua. The accused was also ordered to pay moral damages and civil indemnity.
Can the accused be compelled to acknowledge the child?	The Supreme Court clarified that Angel Amante could not be compelled to acknowledge the child because he claimed to be married, and the prosecution did not present any evidence to the contrary. His civil status prevented him from legally recognizing the child.

The Supreme Court’s decision in People v. Amante provides a clear reminder of the legal standards applied in rape cases and the importance of protecting victims’ rights. It reinforces the principle that a credible testimony from a rape victim is sufficient for conviction and that delays in reporting due to fear should be duly considered. The award of moral damages and civil indemnity further acknowledges the severe trauma inflicted on the victim.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines v. Angel Amante, G.R. Nos. 149414-15, November 18, 2002