PEOPLE v.

GABRIEL
GR No. 213390 (March 15, 2017)

FACTS:

1. Plaintiff AAA is a 17 year old nursing student temporarily residing in the boarding house of the
accused-appellant in Quezon City.
2. At about 6:00 PM of February 17, 2010, she, with her cousin and co-boarder ''BBB," was inside
their room at the second floor of the said boarding house when appellant suddenly entered
their room and accused them of having stolen items of merchandise from his store located near
the said boarding house.
3. AAA and BBB both vehemently denied the accusation of the accused, who then directed them to
see him in his room at the first floor of the boarding house to talk about the matter.
4. When AAA entered the room, the accused insisted on his allegations and threatened to bring
her to the police station and have a theft case against her blottered.
5. The accused then asked AAA to sit on her lap as he caressed her back. When AAA stood up to
leave, appellant pulled her back, compelled her to sit on his lap anew, and then proceeded to
unhook her bra and rape her.
6. The accused only released AAA after the child of the accused knocked on the door. AAA then
went to the bathroom to wash and then returned to her room at the second floor where she
continued to cry. Her cousin BBB asked why she was crying but could not tell her of her forcible
violation.
7. Later that evening the relatives of AAA went to the boarding house to confront the accused
regarding his allegation of theft. It is only then that AAA told her relatives that she has been
raped by the accused.
8. The police then arrested the accused, who was charged with rape after a medico-legal exam
showed that AAA had indeed been sexually abused.
9. The accused was convicted by the Regional Trial Court, whose ruling was later affirmed by Court
of Appeals.
10. Even if there was no other witness to the crime other than the victim herself, both courts gave
more weight to the sole testimony of AAA than the bare denial of the accused.

ISSUE:

Whether the sole testimony of the rape victim is enough to find the accused guilty of rape

RULING:

YES. In the 1901 case of United States v. Ramos, the Court declared that "[w]hen a woman
testifies that she has been raped she says, in effect, that all that is necessary to constitute the
commission of this crime has been committed. It is merely a question then, whether or not this
court accepts her statement.

The Supreme Court upheld the findings of fact of the RTC, which relied on the sole testimony of
the victim, because of its direct, immediate and first hand opportunity to observe the
deportment of witnesses as they delivered their testimonies in open court. Thus the trial court's
findings bearing on the credibility of witnesses on these matters are invariably binding and
conclusive upon the appellate court unless there is a showing that the trial court had
overlooked, misapprehended or misconstrued some fact or circumstance of weight or
substance.

The Court also took into consideration the inherent weakness of the defense of the accused as
compared with the straightforward but specific testimony of the plaintiff. The Court cited the
CAs ruling on the issue that denial is inherently a weak defense which cannot outweigh
positive testimony. As between a categorical statement that has the earmarks of truth on the
one hand and bare denial, on the other, the former is generally held to prevail.