Jurisprudence for rape cases

G.R. Nos. 135454-56 November 13, 2001

PEOPLE OF THE PHILIPPINES, appellee,

vs.
RODERICK SANTOS y YAMAT, appellant.

PANGANIBAN, J.:

Delay in reporting a rape does not necessarily taint the victim's testimony,
provided it is satisfactorily explained, as in this case.

Appellant faults private complainant for her unreasonable and unjustified

delay in reporting the alleged crimes. He casts serious doubts on her true
motive by pointing out that she filed14 the three charges more than four years
after the first rape had supposedly taken place. He likewise questions her
credibility by citing material inconsistencies in her testimony.
14 The cases were filed on October 23, 1997.

We disagree. We have consistently held that the assessment of the credibility of

witnesses and their testimonies is best left to the trial court because of its
unique opportunity to observe them firsthand and to note their demeanors and
attitudes on the witness stand. Hence, its findings are accorded great weight
and deemed binding and conclusive on appellate courts, unless some facts or
circumstances of weight and substance have been overlooked or
misinterpreted.15
15 People v. Raul Tagaba and Jaime Tolibas, GR Nos. 112792-93, October 6,

2000, per Quisumbing, J .

delay in reporting a crime of rape has not always been construed as an

indication of a false accusation.16 In fact, this Court has repeatedly held that it
is not uncommon for young girls to conceal for some time the assault on their
virtue because of the rapist's threat on their lives. x x x [R]ape is a traumatic
event, and the shock concomitant with it may linger for a while.17

16 People v. Alimon, 257 SCRA 658, June 28, 1996.

17 People v. Malabago, 271 SCRA 464, April 18, 1997.

G.R. No. 146327-29 June 5, 2002

PEOPLE OF THE PHILIPPINES, appellee,
vs.
ERNIE BARO, appellant.

PANGANIBAN, J.:

In rape, the complainant's delayed disclosure of the crime to kith or kin or

persons of authority does not always warrant the conclusion that the woman
was not sexually molested or that her charges against the accused are baseless
and fabricated.17 However, the delay must be adequately and satisfactorily
explained; otherwise, it would generate doubt as to the guilt of the accused.18

17 People v. Garcia et. al., 105 SCRA 6, June 11, 1981.

18 People v. Cueto, 84 SCRA 774, August 25, 1978.