The defense's effort to undermine Marites' credibility by

pointing out the one month delay in reporting the sexual assault
upon her also proves futile in view of the justification provided by
Marites. She chose to suffer in silence and not to reveal her
deplorable experience to a single soul until one month after that
fateful day in May for fear that the appellant would carry out his
threat to kill Marites' whole family if she reported the rape incident.
By June 26, 1996, however, the appellant had left for Manila.
Believing that the appellant no longer posed a threat to her family,
Marites finally revealed her agonizing experience to her parents and
reported it to the police authorities. In a number of cases, the
Court has held that delay or vacillation in filing criminal
charges does not necessarily undermine the credibility of
witnesses if such delay is satisfactorily explained. Among the
reasons considered sufficient by the Court are fear of reprisal,
social humiliation, familial considerations and economic
reasons. The Court declared that it was understandable that a
fourteen-year old rape victim, similar to Marites, would be cowed
into silence as the accused warned her that she would be killed if
she divulged the incident to anybody.[People v. Lusa, 288 SCRA
296 (1998), citing People v. Fuensalida, G.R. No. 119963,
November 6, 1997.]
Evidence to be believed must not only come from a credible
source but must also be credible in itself such as one that the
common experience and observation of mankind can approve as
probable under the circumstances. (People vs. Biane Bontuan,
G.R. No.s. 142993-94, September 5, 2002; Ynares-Santiago, J.)
At any rate, ill-motive is never an essential element of a
crime. It becomes inconsequential in a case where there are
affirmative and categorical declarations towards the accusedappellants accountability for the felony. (People vs. Biane
Bontuan, G.R. No.s. 142993-94, September 5, 2002; YnaresSantiago, J.)
Be that as it may, accused-appellant may be convicted on the
basis of the lone, uncorroborated testimony of the rape victim,
provided that her testimony is clear, positive, convincing and
otherwise consistent with human nature. When a woman declares
that she has been raped, she says in effect all that is necessary to
mean that she has been raped, and where her testimony passes the
test of credibility, the accused can be convicted on the basis thereof.
This is because from the nature of the crime, the only evidences

that can be offered to establish the guilt of the accused is the

complainants testimony. (People vs. Biane Bontuan, G.R. No.s.
142993-94, September 5, 2002; Ynares-Santiago, J.)
The victims act of crying during her testimony bolsters the
credibility of the rape charge with the verity born out of human
nature and experience. (People vs. Biane Bontuan, G.R. No.s.
142993-94, September 5, 2002; Ynares-Santiago, J.)
The crying of the victim during her testimony is evidence of the
credibility of the rape charge with the verity born out of human
nature and experience. (People vs. Gecomo, 254 SCRA 82[1996]).
Physical evidence are mute but eloquent manifestations of truth and
they rate high in our hierarchy of trustworthy evidence. (People vs.
Uycoque, 246 SCRA 769 [1995]).
It is not necessary for the commission of rape that there be marks of
physical violence on the victims body. (People vs. Ulzoron, 286
SCRA 741[1998]).
Credibility of rape-witness
The well-settled rule is that when the issue is one of
credibility of witnesses, the appellate court will generally not
disturb the findings of the trial court since the latter is in a better
position to decide this issue. However, this rule is not absolute. It is
subject to exceptions. One concerns a situation where the judge
who penned the decision did not personally hear the evidence for
the prosecution. Another exception is where substantial facts and
circumstances have been overlooked which, if properly considered,
would justify a different conclusion or alter the result of the case.
(People vs. Norberto Loreno, et.al., G.R. No. 130889, June 6,
2002)
Delay in reporting
The failure of the victim of rape to report immediately to the
police authorities does not detract from her credibility since her
hesitation could be attributed to her age, the moral ascendancy of
appellant and his threats against the former. (People vs. Abad, 268
SCRA 248 [1997])

Many victims of rape, however, never complain or file

criminal charges against the rapist for they prefer to silently bear
the ignominy and pain rather than reveal their shame to the world
or risk the offenders ire and drive him to carry out his threats.
(People of the Philippines vs. Efren G. Detaza, G.R. Nos.
136286-89, September 11, 2003)
We (SC) do not consider the delay fatal. Delay or vacillation
in making a criminal accusation does not necessarily impair the
credibility of a witness if the delay is satisfactorily explained.
(People of the Philippines vs. Rodolfo Junas, G.R. Nos. 14497273, September 12, 2003)
No standard form of behavior:
Appellant likewise posits that complainant was acting
normally even in his company after the alleged rape incidents. He
cites the instances when he brought Jocelyn to school, when they
celebrated his birthday in Banogs Nest, and when he taught her
how to drive, all of which run counter to the customary reaction of
a victim of such offenses, more so of a minor. It is settled doctrine
in rape cases, however, that no standard form of behavior is
expected, for the workings of a human mind when placed under
emotional stress are unpredictable. (People of the Philippines vs.
Efren G. Detaza, G.R. Nos. 136286-89, September 11, 2003)
How the victim comported herself after the incident was not
significant as it had nothing to do with the elements of the crime of
rape. Furthermore, different people react differently to a given
situation. There is no standard form of behavior when one is faced
with a distressing incident. The workings of the human mind when
placed under emotional stress are unpredictable. In People vs.
Luzorata, this Court indeed has not laid down any rule on how a
rape victim should behave immediately after she has been abused.
This experience is relative and may be dealt with in any way by the
victim depending on the circumstances, but her credibility should
not be tainted with any modicum of doubt. (People of the
Philippines vs. Vicente Binarao, et.al. G.R. Nos. 134573-75,
October 23, 2003)
THE ESSENCE OF RAPE IS CARNAL KNOWLEDGE OF A
WOMAN AGAINST HER WILL. (People of the Philippines vs.
Vicente Binarao, et.al. G.R. Nos. 134573-75, October 23, 2003)

Having admitted to having had carnal knowledge of the

complainant on the date and time in question, the appellant bears
the burden of proving his defense, that she consented to the sexual
act, by clear and convincing evidence. This, he failed to do. No
cogent reason exists to overturn the decision of the trial court. We
sustain appellants conviction for the crime of rape with the use of a
gun, a deadly weapon. (People of the Philippines vs. Joseph
Dizon, G.R. No. 144053, December 11, 2003, Quisumbing, J.)
For the appellee, the OSG contends that appellants sweetheart
theory is nothing but a sham. In the first place, appellant failed to
establish the existence of a romantic relationship. Janice might be a
phone pal but she vehemently denied that she had feelings for the
appellant. According to the OSG, the appellant merely concocted
the alleged romance in order to exculpate him from criminal
liability. But, even granting that they were sweethearts, this fact
would not, by itself, exonerate appellant. (People of the
Philippines vs. Joseph Dizon, G.R. No. 144053, December 11,
2003, Quisumbing, J.)
DAMAGES:
The SC declared that civil indemnity in the amount of P75,000.00
is automatically granted to the offended party in rape cases without
need of further evidence other than the fact of the commission of
rape and the accused responsibility therefor. (People vs. Victor,
G.R. No. 127903, July 9, 1998)
The offended party in rape case is entitled to moral damages which
is automatically granted without need of any proof. It is currently
fixed in the amount of P50,000.00. (People vs. Padilla, 301 SCRA
265 [1999])
Finally, in line with the prevailing jurisprudence, we affirm the trial
courts award of P50,000.00 as civil indemnity, in line with the
current policy of this Court to award civil indemnity ex delicto in
the said amount for each count of rape upon an indubitable
showing of its commission. With respect to the moral damages, the
amount of P50,000.00 is awarded. Moral damages are
automatically granted in rape cases without need of further proof
other than the commission of the crime, because it is assumed that a
rape victim has actually suffered moral injuries entitling her to such
an award. (People of the Philippines vs. Roberto Segovia, G.R.
No. 138974, September 19, 2002, Ynares-Santiago, J.)