Facts:

Leonida B. Francisco, a 62-year-old widow, reported to the Bacoor Police Station in Cavite that she had been raped by her son, Zaldy Francisco y Baron, who was 29 years old at the time of the incident. On the evening of April 17, 1991, after a conversation with a neighbor, Leonida was walking home with a friend when Zaldy informed her that she had a visitor waiting for her. Upon arriving home, she found no one there and asked Zaldy about the visitor. Instead of answering, Zaldy locked the door and insisted that they go upstairs to talk.

Once upstairs, Zaldy accused Leonida of having an affair and threatened her with a knife. Despite her pleas for him to stop, Zaldy physically assaulted her, leading to a series of three rapes over the course of an hour. Leonida described the horrific events, detailing how Zaldy forced her onto the bed, threatened her life, and raped her multiple times. After the assaults, Zaldy made her promise not to tell anyone about the incident before allowing her to leave. The following day, Leonida confided in her daughters and subsequently reported the crime to the police.

On July 2, 1991, an Information for rape was filed against Zaldy in court. Zaldy denied the allegations, claiming that he had only conversed with his mother about some missing money and that he had left the house to "roam around." He suggested that Leonida had a tendency to blame him for various issues and that her accusations were fabricated.

Legal Issues:

  1. Whether the trial court erred in giving credence to the testimony of the complainant, Leonida, and in finding Zaldy guilty of rape.
  2. Whether the evidence presented by the defense was sufficient to create reasonable doubt regarding Zaldy's guilt.

Arguments:

  • Prosecution's Argument: The prosecution relied heavily on the testimony of Leonida, asserting that her account of the events was credible and consistent. They argued that the emotional and psychological trauma she experienced was evident in her testimony, and that the nature of the crime—committed by her own son—provided a strong motive for her to seek justice. The prosecution emphasized that the lone testimony of the victim, if credible, is sufficient for a conviction in rape cases.

  • Defense's Argument: Zaldy contended that the trial court placed undue weight on what he described as inconsistent and unreliable testimony from Leonida. He argued that there was no evidence of a deadly threat during the alleged rapes, and that Leonida did not resist or call for help, which he claimed undermined the prosecution's case. Zaldy also suggested that the incident could not have occurred in a rented room where tenants could return at any moment, implying that the allegations were fabricated.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding Zaldy guilty of raping his mother. The court held that the positive and straightforward testimony of Leonida outweighed Zaldy's self-serving denials. It noted that the credibility of the victim's testimony was bolstered by the shocking nature of the crime, which involved a son raping his own mother. The court dismissed the alleged inconsistencies in Leonida's testimony as minor and attributed them to the trauma of the experience, stating that such discrepancies do not detract from the fact of the rape.

The court emphasized that rape is a heinous crime, particularly when it involves familial betrayal, and that the law recognizes the gravity of such offenses. The court also highlighted that the testimony of the victim is sufficient for conviction, provided it is credible. The court ultimately sentenced Zaldy to reclusion perpetua and ordered him to indemnify Leonida.

Significant Legal Principles Established:

  1. The testimony of a rape victim, if credible, can be sufficient for conviction, even in the absence of corroborating evidence.
  2. Minor inconsistencies in a victim's testimony do not necessarily undermine credibility, especially in cases involving traumatic experiences.
  3. The court recognized the particularly abhorrent nature of incestuous rape, which carries additional moral and legal condemnation.