FACTS:
The case involves the incident where the accused, Rogelio Bondoy, forcibly enters the store owned by Patria V. Sabularce. Bondoy, carrying a sharp knife, nicks Patria's abdomen and demands that she drop the robbery charge she had filed against him. Despite Patria's refusal, Bondoy proceeds to rape her in front of her children. He is later arrested by the police and an information for rape with the use of a deadly weapon is filed against him. The prosecution presents evidence of the force and intimidation used by Bondoy during the rape, as well as his threats to kill Patria and her children if she does not withdraw the robbery charge. Bondoy orders Patria and her children to the store after the rape, intending to make them go to town to withdraw the case. However, Patria informs him that she cannot withdraw the case.
During the incident, Bondoy allegedly stabs Patria multiple times, causing her injuries. He had broken into Patria's house and threatened her with a sharp instrument, demanding that she withdraw the case against him. Both Bondoy and Patria were reportedly in their underwear during the altercation. Patria's nephew, Rommel, witnesses the incident and intervenes but is also attacked by Bondoy. In the struggle, Patria manages to grab the knife from Bondoy and stabs him near the armpit. In retaliation, Bondoy stabs Patria in her right forearm. They both shout for help, and Bondoy flees, leaving behind his t-shirt. Witnesses in the area respond to Patria's cries for help and offer assistance. Patria is taken to the hospital, where medical examinations reveal her injuries and the presence of spermatozoa in her vaginal opening. The defense attempts to argue that Bondoy and Patria were lovers, suggesting that their intimate relationship negates the possibility of rape or non-consensual sexual intercourse.
The case also involves a marital dispute between Emelita and her husband. Emelita testifies that on the night in question, her husband asked her to watch his motorboat. However, due to a toothache, she instead went to Patria's store to buy medicine. As she approached the store, she overhears someone crying and decides to peep through a hole. She witnesses Patria sitting on her husband's lap, with her head resting on his chest, expressing her emotions to Emelita's husband.
ISSUES:
-
Whether the prosecution has proven the guilt of the accused beyond reasonable doubt for the crime of rape with physical injuries and use of a deadly weapon.
-
Whether the defense of consensual sexual relationship between the accused and the victim is credible.
-
Whether the lower court erred in finding that the accused had sexual intercourse with the complainant.
-
Whether the lower court erred in giving credence to the testimonies of the prosecution witnesses.
-
Whether the lower court erred in finding the accused guilty of the crime and/or the prosecution was able to prove his guilt beyond reasonable doubt.
-
Whether the testimonies of the prosecution witnesses, despite being related to the complainant, are credible evidence of the appellant's guilt beyond reasonable doubt.
-
Whether the alleged amorous relationship between the appellant and the complainant is a valid defense against the charge of rape.
-
Whether the crime committed should be deemed as "rape with physical injuries and use of deadly weapon" or just "rape."
-
Whether the penalty imposed by the lower court and the amount of damages awarded to the complainant are appropriate.
RULING:
-
The court finds the accused guilty beyond reasonable doubt of the crime of rape with physical injuries and use of a deadly weapon. The medical certificate presented by the prosecution established that the victim sustained an incised wound and multiple abrasions, which could have been caused by a sharp instrument. The presence of sperm cells in the vaginal discharge further supports the prosecution's claim. The aggravating circumstances of the crime being committed in the dwelling of the victim without provocation, after unlawful entry, and with the use of a broken wall were also proven.
-
The defense of consensual sexual relationship between the accused and the victim is not credible. The testimonies of the defendant's wife and brother-in-law contradicted the defense's claim of a consensual relationship. The accused also admitted to "using" the victim during their relationship, undermining the defense's argument.
-
The Court upheld the decision of the lower court and affirmed the conviction of the accused for the crime of rape. The accused was sentenced to suffer the penalty of reclusion perpetua and ordered to pay moral damages and exemplary damages to the complainant. The Court held that the complainant's testimony, even if uncorroborated, was sufficient to justify a conviction for rape as long as it was credible and positive. The Court stated that when a woman says that she has been raped, she says all that is necessary to show that rape was indeed committed. The Court found no reason to doubt the veracity of the sexual intercourse forced by the accused upon the complainant. The Court also emphasized that the presence or absence of spermatozoa in the vagina is not determinative of the commission of rape.
-
The testimonies of the prosecution witnesses, despite being related to the complainant, are credible evidence of the appellant's guilt beyond reasonable doubt. The fact that they are related to the complainant does not weaken the prosecution's theory of the crime as long as their testimonies are not inherently improbable.
-
The alleged amorous relationship between the appellant and the complainant is not a valid defense against the charge of rape. The complainant's conduct after the crime, such as immediately reporting it to the police and undergoing an examination, contradicts the existence of a consensual relationship.
-
The crime committed should be deemed as "rape" and not "rape with physical injuries and use of deadly weapon." The physical injuries sustained by the complainant are part of the commission of the crime of rape and do not require separate treatment in this case. The ambiguity in the information filed should be resolved in favor of the accused.
-
The penalty of reclusion perpetua and the amount of damages awarded to the complainant are appropriate. The aggravating circumstances of dwelling and unlawful entry warrant the imposition of reclusion perpetua, while the constitutionally banned penalty of death is deemed inapplicable. The complainant is entitled to moral damages, and the amount of fifty thousand pesos (P50,000.00) is appropriate indemnity for the commission of the crime.
PRINCIPLES:
-
In a criminal case, the prosecution bears the burden of proving the guilt of the accused beyond reasonable doubt.
-
The presence of physical injuries and corroborating evidence can be used to establish the commission of a crime.
-
Aggravating circumstances can increase the penalty for a crime.
-
The testimony of a rape victim, if credible and positive, is sufficient to justify a conviction for rape, even if uncorroborated.
-
The presence or absence of spermatozoa in the victim's body is not determinative of the commission of rape. What is important in rape is penetration of the pudenda and not emission of seminal fluid.
-
The trial court's evaluation of the credibility of witnesses deserves utmost respect, particularly when it had the advantage of directly observing their demeanor in court.
-
The testimony of a rape victim, coupled with circumstantial evidence and the testimonies of other witnesses, can establish the guilt of the accused beyond reasonable doubt.
-
The existence of an amorous relationship between the accused and the complainant does not negate the possibility of rape if the victim's behavior after the crime suggests a desire to seek justice.
-
Ambiguities in the information filed should be resolved in favor of the accused.
-
The penalty imposed should consider both aggravating and mitigating circumstances, and the constitutionally banned penalty of death cannot be imposed.
-
A rape victim is entitled to indemnity for moral damages.
-
The credibility of witnesses should be assessed based on their testimonies, regardless of their relationship with the complainant or accused.