GR 173798; (December, 2010) (Digest)
G.R. No. 173798 ; December 15, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RENE CELOCELO, Accused-Appellant.
FACTS
The prosecution’s case established that in the early morning of July 26, 1998, in Las Piñas City, accused-appellant Rene Celocelo entered the house of the 19-year-old victim, AAA, while she was sleeping. He covered her mouth, warned her not to make a scandal, and dragged her by the hair to an outside comfort room. There, while pointing a knife at her, he forced her to undress and had carnal knowledge of her against her will. AAA immediately reported the incident, leading to Celocelo’s arrest. Medico-legal examination confirmed a contusion on her right breast and the presence of spermatozoa, corroborating recent sexual intercourse.
The defense presented a starkly different version. Celocelo claimed he and AAA were in a romantic relationship and that the sexual encounter on the same date was consensual. He testified that AAA willingly led him to the comfort room and that no force or intimidation was employed. His brother-in-law, Edgardo de Vera, supported this claim by testifying to their prior friendly interactions.
ISSUE
The core issue is whether the prosecution proved beyond reasonable doubt that the sexual intercourse was achieved through force or intimidation, constituting the crime of rape.
RULING
The Supreme Court affirmed the conviction. The Court gave greater weight to the credible, straightforward, and consistent testimony of the victim over the denial and implausible claim of a romantic relationship by the accused. AAA’s detailed account of being suddenly awakened, dragged, and threatened with a knife was found to be natural and convincing. The medico-legal findings of a contusion and the presence of spermatozoa provided physical corroboration of a violent assault, consistent with her narrative.
The defense of a sweetheart relationship was rejected for being inherently unbelievable and unsupported by credible evidence. The Court noted that such a defense is often fabricated in rape cases and found no proof of a courtship that would explain AAA’s willingness. Her prompt reporting of the crime and emotional distress further bolstered her credibility. The element of carnal knowledge through force or intimidation was thus established beyond reasonable doubt. The penalty of reclusion perpetua was affirmed, and the award of damages was modified to include exemplary damages.