PEOPLE OF THE PHILIPPINES, vs. EDUARDO ULILI.
- G.R. Number: G.R. No. 103403
- Promulgated: 1993-08-24
- Ponente: Regalado, J.
Doctrine
In rape prosecutions, conviction may properly be based solely on the accurate and credible testimony of the offended party; additional witnesses are not always required.
A medical certificate or physician's testimony is not indispensable to prove rape; it primarily serves to show loss of virginity and may corroborate the complainant's testimony.
Minor inconsistencies in witness testimony on collateral matters do not negate the substance or weight of their declarations and may even strengthen credibility.
Facts
The accused, Eduardo Ulili, was found guilty beyond reasonable doubt of the crime of rape and sentenced to reclusion perpetua, indemnity, attorney's fees, child support, and costs.
The People's brief recounts that Beverly T. Pelaez was employed by appellant as a salesgirl and was transferred on 3 December 1989 to Esperanza, Sultan Kudarat where appellant had a dry goods store.
The complainant was unconscious at the time she was raped, permitting the accused to consummate the act unimpeded.
The police blotter extract (Exhibit D), complainant's letter to her sister-in-law (Exhibit A), and a medical certificate (Exhibit B) were considered corroborative though not indispensable.
Issues
Whether the conviction of the accused for rape is supported despite inconsistencies and limited corroborative evidence.
Whether the amount of indemnity awarded should be modified.
Ruling
The Court found the accused guilty beyond reasonable doubt of rape and imposed reclusion perpetua, indemnity, attorney's fees, monthly support for the offspring, and costs.
The trial court's judgment is affirmed, with modification increasing the indemnity to P30,000.00.
Keywords
G.R. No. 103403, PEOPLE OF THE PHILIPPINES v. EDUARDO ULILI, rape, Criminal Case No. 1902, Regional Trial Court of Isulan, Sultan Kudarat, guilty beyond reasonable doubt, reclusion perpetua, indemnify the offended party, damages (Article 2219, New Civil Code of the Philippines), attorney's fees, support the offspring, sworn complaint, medical certificate, Hymenal Lacerations at 4 and 9 o'clock positions, fresh with granulations, police blotter, denial, conviction, prosecution's evidence, defense, store