PEOPLE OF THE PHILIPPINES, vs. AUGUSTO CHING .
- G.R. Number: G.R. No. 103800
- Promulgated: 1995-01-19
- Ponente: Regalado, J.
Doctrine
In rape prosecutions, conviction or acquittal virtually depends on the credibility of the victim; the lone credible testimony of the victim is sufficient to sustain conviction.
A party asserting affirmative allegations must prove them; failure to establish an alternative explanation for physical injuries weakens the accused's defense.
Findings of the trial court on witness credibility are entitled to great weight on appeal.
Facts
An information for rape was filed against appellant Augusto Ching for carnal knowledge of Maria Theresa Decolongon, alleged to have occurred on the evening of 14 December 1989 in Barangay Debangan, Taytay, Palawan; the complainant was then ten years old.
The victim immediately informed Labarosa of the rape, but he ignored her; Labarosa later gave inconsistent explanations about what he was told and his observations that night.
The complainant testified she saw appellant hold her nose and mouth, lie on top of her with his pants lowered, that he touched her private parts before she lost consciousness, and later she saw bloodstains on her underwear.
Issues
Whether the lone testimony of the victim, if credible, is sufficient to sustain a conviction for rape.
Whether the prosecution proved carnal knowledge and rebutted appellant's affirmative defenses and attacks on credibility.
Ruling
Yes. The Court held that conviction in rape cases virtually depends on the victim's credibility and that the lone credible testimony of the victim is sufficient to sustain conviction; the trial court's credibility findings are entitled to great weight.
Yes. The Court found the fact of carnal knowledge amply established by the complainant's detailed testimony and physical evidence (bloodstains, hymenal laceration) and held that appellant failed to prove alternative causes or rebut the prosecution's case; the appealed judgment is affirmed in toto.