People v. Fajardo
REITERATIONFacts
The Antecedents: The complainant alleged that while walking home, the accused accosted her, held her arm, and upon her retort, boxed her in the stomach, causing her to fall unconscious. When she regained consciousness, she was naked, and the accused was zipping his shorts before fleeing. She reported the incident to her aunt, then to her father, who subsequently reported it to the barangay captain and the police. Medical examinations were conducted by Dr. Cruz and later by Dr. Salvador of the NBI. Dr. Cruz found old lacerations and advised a vaginal smear, not discounting rape. Dr. Salvador found fresh, healing lacerations consistent with sexual intercourse within two to three days prior to examination, concluding the injuries were healing. The complainant suffered sleepless nights, wounded feelings, and besmirched reputation. Procedural History: The Regional Trial Court found the accused Siegfred Fajardo guilty beyond reasonable doubt of rape, sentencing him to reclusion perpetua and ordering him to indemnify the offended party P50,000.00. The Petition: The accused appealed the decision, arguing inconsistencies in the complainant's testimony, that the genital findings were not consistent with rape, that the trial court erred in overruling the private practitioner's findings, in not believing the accused's theory, and in finding the accused as the perpetrator.
Issue(s)
Whether the alleged inconsistencies in the complainant's testimony impair her credibility. Whether the genital findings are consistent with rape. Whether the trial court erred in giving greater weight to the NBI's medical findings over those of a private practitioner. Whether the accused is guilty beyond reasonable doubt of the crime of rape.
Ruling
The Court affirmed the conviction for rape but reduced the indemnity from P50,000.00 to P20,000.00.
Ratio Decidendi
On the alleged inconsistencies in the complainant's testimony: The Court found the alleged inconsistencies to be flimsy and minor. The discrepancy regarding whether a conversation transpired when the accused accosted the complainant was deemed insignificant, as the accused's statement of love was not a substantial conversation. Similarly, the slight variation in the estimated time of the incident (7:00 p.m. versus reaching the scene around 6:00 p.m.) was considered understandable, as such estimates are not based on precise timekeeping. These minor discrepancies did not impair the complainant's overall credibility, especially when weighed against the substantial evidence presented. On whether the genital findings are consistent with rape: The Court relied on the NBI medico-legal's findings, which concluded that the hymenal lacerations were fresh and healing, consistent with recent sexual intercourse. While Dr. Cruz found old lacerations, he did not discount the possibility of rape and suggested a vaginal smear. The NBI's findings, indicating recent injuries, directly supported the complainant's allegation of rape. On giving greater weight to the NBI's medical findings: The Court found no error in giving greater weight to the NBI physician's findings. Dr. Salvador, as an NBI medico-legal, is a disinterested witness and enjoys the presumption of regularity in the performance of his official duty. In contrast, Dr. Cruz, a private practitioner, was suspected of bias due to alleged relationship with the accused, and his refusal to provide a copy of his medical certificate further diminished his credibility. The NBI's examination, conducted by a specialized agency, was deemed more reliable. On the guilt of the accused beyond reasonable doubt: The Court found the complainant's testimony credible, supported by physical evidence such as torn and bloody clothing, an abrasion on her breast, and fresh hymenal lacerations. The accused's defense, which relied on a questionable account of an embrace and a denial of the relationship, was found to be incredible. The Court concluded that the evidence presented by the prosecution established the guilt of the accused beyond reasonable doubt, consistent with the trial court's findings.
Main Doctrine
The Court affirmed the conviction for rape but reduced the indemnity, giving greater weight to the NBI's medical findings over those of a private practitioner suspected of bias, and found minor inconsistencies in the complainant's testimony did not impair her credibility.