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"x x x.
The elements necessary to sustain a conviction for rape are: (1) that the accused had carnal knowledge of the victim; and (2) that said act was accomplished (a) through the use of force or intimidation, or (b) when the victim is deprived of reason or otherwise unconscious, or (c) when the victim is under 12 years of age or is demented.[17]
The prosecution sought to establish the presence of these elements through the testimony of the victim herself. The testimony, here found credible, paves way for the affirmance of the conviction of the accused. In a prosecution for rape, the victim’s credibility becomes the single most important issue. For when a woman says she was raped, she says in effect all that is necessary to show that rape was committed.[18]
We affirm the finding of guilt as we once more say that the trial court is in a better position to decide the question as it heard the witnesses themselves and observed their deportment and manner of testifying during trial.[19]
After a thorough examination of the records, we agree with the factual findings of the RTC, as affirmed by the Court of Appeals, on the credibility of AAA’s testimony. AAA did not waver in pointing to appellant as her assailant. She was straightforward and unequivocal in narrating how she was raped by appellant xxx."
All elements of rape under Article 266-A of the Revised Penal Code[21] were sufficiently proved through the statement of AAA alone. The offender is a man who had carnal knowledge of AAA when he forced himself upon the latter. Appellant accomplished his purpose through the use of threat,i.e. threatening to kill AAA. In fact, it is under these same threats that AAA was not able to resist nor summon for help x xx."
The inconsistency of AAA’s statement pertaining to the presence of BBB at the crime scene can be easily dismissed, as it was dismissed by the appellate court in this wise:
Clearly, the question of whether the victim’s mother was in their house at the time of the rape or not is immaterial in proving the guilt or innocence of the accused-appellant. Hence, such minor inconsistency in the witness-victim’s testimony cannot be a ground to destroy her credibility or more so, serve as basis for accused-appellant’s acquittal.[23]
Indeed, the presence of BBB at the locus criminis is of no moment. It is not an essential element to establish the crime of rape. The inconsistent statements of AAA pertaining to BBB may be attributed to the fact that she was very confused at that time and she is not expected to remember each and every detail of the events that transpired that day, especially matters which are trivial and inconsequential.
The appellate court is likewise correct in downplaying the medico-legal findings which it ruled as “merely corroborative in character and is not an element of rape.”[24] The prime consideration in the prosecution of rape is the victim's testimony, not necessarily the medical findings; a medical examination of the victim is not indispensable in a prosecution for rape. The victim's testimony alone, if credible, is sufficient to convict.[25]
Under Article 266-B of the Revised Penal Code, rape under paragraph 1 of Article 266-A is punishable by reclusion perpetua. The trial court therefore correctly imposed the penalty. We likewise affirm the award of civil indemnity of P50,000.00 and moral damages amounting to P50,000.00. Civil indemnity is mandatory when rape is found to have been committed while moral damages are awarded to rape victims without need of proof other than the fact of rape on the assumption that the victim suffered moral injuries from the experience she underwent.[26] An additional award of P30,000.00 as exemplary damages should likewise be given, as well as interest of six percent (6%) per annum on all damages awarded from the finality of judgment until fully paid.[27]
