In support of his argument, appellant impugns the victims' credibilities by
capitalizing on the alleged inconsistencies in their open court testimonies; their
failure to shout for help during the alleged incidents; the belated filing of their
complaints; and, the medical finding of no evident injury during their examination.
Our Ruling
The appeal lacks merit.
The inconsistency pointed out by appellant as to whether "AAA" was alone or with
"BBB" during the alleged incident on the first week of October 2001 refers merely to
inconsequential matter that will not affect the determination of whether appellant is
innocent of the crime charged or not. "[D]iscrepancies referring only to minor
details and not to the central fact of the crime do not affect the veracity or detract
from the credibility of a witness' declaration x x x."[14] Respecting the alleged
inconsistency on whether appellant's penis touched “AAA's" vagina or not, the same
has been clarified by "AAA" herself.[15] "AAA" stated that appellant's penis indeed
brushed her vagina. As held in Dizon v. People,[16] "[i]n rape cases, the testimony
of [the] complainant must be considered and calibrated in its entirety, and not in its
truncated portion or isolated passages thereof. The true meaning of answers to
questions propounded to a witness is to be ascertained with due consideration of all
the questions and answers given thereto. The whole impression or effect of what
has been said or done must be considered, and not individual words or phrases
alone. Facts imperfectly stated in answer to a question may be supplied or clarified
by one's answer to other questions."
The failure of the victims to shout for help or escape during the incidents does not
undermine their credibility. It is not also fatal to the prosecution's case. “[N]o
standard form of behavior can be anticipated of a rape victim following her
defilement, particularly a child who could not be expected to fully comprehend the
ways of an adult. People react differently to emotional stress, and rape victims are
no different from them."[17]
Neither the delay in reporting the incidents to the proper authorities tainted the
victims' credibility. For sure, there was no prompt revelation of what befell the
victims. But "long silence and delay in reporting the crime of rape have not always
been construed as indications of a false accusation."[18] "A rape charge becomes
doubtful only when the delay in revealing its commission is unreasonable and
unexplained."[19] In the present case, appellant threatened the victims that he
would kill them and their families if they would tell anyone of what he did to them.
To our mind, this is a reasonable explanation for the delay.