People vs.

Bulos
FACTS:
Both the offended party and the accused are working for spouses Mario and Delia Fariolan, who reside in Barangay Dujali, Panabo, Davao. The offended party was the cook and general househelp while the accused worked as a truck helper for the business of Mario Fariolan; they both stayed in the house of the Fariolans. As testified to by Nancy Cordero, at about 3:00 in the afternoon of December 3, 1992, she was in her room folding laundry when the accused suddenly entered, locked the door from inside, and closed the window. At the time, the Fariolans were out of the house. She attempted to flee but the accused grabbed her and threatened her with a hunting knife. Nancy shouted for help, but the accused told her to stop shouting or he will kill her. She lost consciousness and when she came to, she found him on top of her and having carnal knowledge of her. Soon after, a certain "Bong" or "Bobong", the accused's uncle who allegedly served as a lookout, knocked on the door and warned that the Fariolans might be returning anytime soon. Before he left her, the accused threatened the victim not to report the incident to anyone. After he had gone, Nancy examined herself and discovered that she was bleeding. She did not dare tell anyone but wept alone in pain and anger. At 5 o'clock the next morning, Nancy left the Fariolan residence for her house, also in Barangay Duwali, where she told her mother of what happened. Immediately they reported the incident to the barangay captain. On the same day, the accused also left the house of the Fariolans and was nowhere to be located.He only turned up on December 14, 1992, Upon which he was immediately arrested.

ISSUE: Whether or not the lone testimony of the victim in rape cases are competent to establish guilt of the accused. RULING:
It is doctrinally settled that the lone testimony of the rape victim herself is competent to establish guilt, where the same is found to be credible, convincing, and consistent with human nature and the normal course of things.This is because from the nature of the offense, the only evidence that can oftentimes be offered to establish the guilt of the accused is the complainant's testimony. The Court also considers that ordinarily, no woman would be willing to undergo the humiliation of a public trial and testify to the details of her ordeal were it not but a response to the compelling need to seek and obtain justice. There is nothing in this case to indicate that Nancy Cordero, an 18-year old cook and house helper, would have any motive to falsely implicate the accused, in the process admitting to the stain to her modesty and honor, and losing her humble means of employment; the logical conclusion is that her testimony is worthy of full faith and credence. Furthermore, Nancy's statements are corroborated by the medical certificate, which confirmed the presence of healed vaginal lacerations. When testimony of rape is supported by physical findings of penetration, there is sufficient foundation for concluding that there was carnal knowledge. Lacerations, whether healed or fresh, are the best physical evidence of forcible defloration. We also join the observation of the trial Court that Nancy Cordero's conduct after the rape renders credibility to her accusations. We have held that the conduct of the victim immediately following the assault is of utmost importance in establishing the truth or falsity of the charge of rape.Here, Nancy lost no time in fleeing the Fariolan residence to seek the help of her mother, and together report the matter to the authorities. A gratuitous disclaimer by accused-appellant cannot prevail over the positive identification of the offended party, more so if the alibi is corroborated only by the accused's relatives and friends. Accusedappellant argues that the Fariolan spouses, as the employers of both the offended party and accused-appellant, were not only unbiased witnesses but even shared with the offended party an interest in having the perpetrator brought to ,justice as the rape was also effectively a desecration of their home. This argument is unacceptable, however, in light of the spouses' active involvement in persuading Nancy to accept accused-appellant's offer of marriage. It is certainly revealing of which employee they favor, and where their biases lie. The Court also takes into consideration the flight of accused-appellant the day after the rape, and his offer of marriage to the victim after the incident had been reported to the authorities. As a rule in rape cases, an offer of marriage to the offended party is an admission of guilt. Piaga, Richard S.