PEOPLE Vs Barcelona Digest

People v, Barcelona
Facts:
Gideon Barcelona y Dequito was charged with the crime of Rape and denied that he committed the crime. The
accused interposed the defense of alibi.
He alleged since complainant saw him, she did not positively identified (sic) him but entertained doubts as the
person who raped her.
"In addition to this, witness Jose Lagrada testified that he was the companion of the accused at the fishing outfit
of Paning Paner. He claimed that from the last week of October 1985 up to his arrest on November 9, 1985,
accused Barcelona never went to the Poblacion of Roxas, Palawan and continuously stayed at Cabugan Island.
Despite prior knowledge that the latter was arrested for rape, he never informed the Police Force of Roxas,
Palawan or any person for that matter about the stay of Barcelona in their place of work nor did he visited (sic)
accused in jail despite his close friendship with him.
Contentions:
(1) in giving weight to the testimony of the complainant which is allegedly materially inconsistent, contradictory
and incredible, and (2) in convicting the accused-appellant when there is no evidence on record that his guilt has
been proved beyond reasonable doubt.
Issue:
Whether the appellant’s identity as the the one who committed the rape was proved beyond reasonable doubt.
Ruling:
There is no doubt that the complainant had been raped on 7 November 1985, in the manner testified to by her and
affirmed by the trial court. When a woman testifies that she has been raped, she says in effect all that is necessary
to show that rape was committed, for no young and decent Filipino woman would publicly admit that she has been
criminally ravished unless that is the truth, for her natural instinct is to protect her honor.
Besides, complainant's testimony is confirmed by the surrounding physical facts.
As to the identity of the perpetrator of the dastardly act, the complainant declared, and the trial court agreed with
her, that the appellant committed the crime. The complainant positively identified the accused as the person who
raped her and, as the trial court said, she had no doubt nor second thought about her identification of the accused-
appellant.
Besides, it would appear that the complainant had no ill motive to testify falsely against the appellant. In fact, the
appellant was a complete stranger to her and she did not know his name then. But, when they came face to face,
the second time, she readily pointed to the appellant as the person who ravished her. This Court has consistently
held that the testimony of a rape victim as to who abused her is credible where she has no motive to testify falsely
against the accused.
Moreover, the outrage was immediately reported to the police authorities after its commission, removing any
doubt that the complainant may have concocted her charge against the appellant.
The appellant argues that the testimony of the complainant should not be given weight and credence because it is
allegedly inconsistent, contradictory and incredible.
These alleged contradictory statements are not fatal as they refer to relatively minor details, and they are to be
expected from uncoached witnesses. They do not affect, nor can they prevail over the positive identification of the
appellant as the rapist. As repeatedly held by the Court, discrepancies and inconsistencies in the testimony of
prosecution witnesses which refer to minor details do not impair the probative value of their testimony. The
insinuation of the appellant that he could not have raped the complainant on 7 November 1985 because it was his
birthday is, definitely, without basis for a man overcome by perversity and beastly passion chooses neither time,
place, occasion nor victim.
The insinuation of the appellant that he could not have raped the complainant on 7 November 1985
because it was his birthday is, definitely, without basis for a man overcome by perversity and beastly
passion chooses neither time, place, occasion nor victim.

PEOPLE Vs Barcelona Digest

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People v, Barcelona

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