G.R. No. 94703 May 31, 1993
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROBERTO OLIQUINO alias “Berto”, defendant-appellant.

FACTS

Complainant Eden Argudo, a 20-year-old college student, was brought by her mother, Tarciana Argudo, to defendant-appellant Roberto Oliquino, a faith healer and her mother’s “compadre,” for treatment of stomach pain. On August 5, 1988, during a treatment session at appellant’s new and isolated house near a mountain, appellant instructed Tarciana to stay inside and pray while he took Eden to the foot of the mountain at the back of his house. There, appellant pointed a knife at Eden’s neck, threatened her, and proceeded to have carnal knowledge of her against her will. Afterward, he threatened to kill her and her parents by putting a curse (“kulam”) if she reported the incident. Eden’s behavior changed afterward; she became depressed, cried often, and became hysterical when appellant was later summoned to treat her at her home. In November 1988, after Eden started vomiting, she revealed the rape to her parents. A medical examination confirmed a hymenal laceration and pregnancy. A complaint for rape was filed in November 1988, approximately three months after the incident. During the trial, Eden suffered a miscarriage. The Regional Trial Court convicted appellant of rape and sentenced him to reclusion perpetua and indemnity. Appellant appealed, claiming the prosecution failed to prove guilt beyond reasonable doubt, that the conviction was based on mere presumptions, and that Eden’s testimony was not credible due to the delay in reporting.

ISSUE

Whether the prosecution proved the guilt of the appellant for the crime of rape beyond reasonable doubt, notwithstanding the delay in filing the complaint and the appellant’s defenses.

RULING

The Supreme Court AFFIRMED the trial court’s decision. The Court held that the delay in filing the complaint three months after the incident did not render Eden’s testimony incredible. Her fear, caused by appellant’s threat to kill her and her parents by putting a curse, was a valid reason for the delay, especially given her youth and the trust her family had in appellant as a faith healer. The Court found Eden’s testimony to be credible, logical, and consistent, and noted that no young Filipina would admit to being raped unless it were true. The Court rejected appellant’s claim that Eden had an ulterior motive to protect a boyfriend, finding it absurd and unsupported by evidence. The Court also found no merit in appellant’s defense that the rape could not have occurred at his house because it was surrounded by neighbors, as it was established that he had moved to a new, isolated residence near a mountain by the time of the incident. The conviction was based on the strength of the prosecution’s evidence, not on presumptions.