PEOPLE v. EDGAR BAYRON Y MANTILLA

FACTS:

The case involves a petition for review of the decision of the Regional Trial Court of Butuan City (Branch 1) finding the accused-appellant guilty of rape and sentencing him to reclusion perpetua and to pay the complainant P50,000.00 as moral damages. The information against the accused-appellant alleged that on or about 12:30 o'clock in the early morning of January 16, 1994, at Tabu-an Section, Langihan, Butuan City, Philippines, the accused-appellant, by force and intimidation, had carnal knowledge with the complainant against her will. The prosecution's evidence presented showed that the complainant, a married woman with three children, slept in her fruit and vegetable stall at the Langihan public market every Saturday night to open her store early on Sundays. On the evening of January 15, 1994, the complainant was in her stall lying on a bamboo bench when the accused-appellant, who had used the stall as his sleeping quarters on previous Saturdays, entered the stall and was surprised to find the complainant there. The accused-appellant left but returned armed with a knife. He then ordered the complainant to lie down and proceeded to have sexual intercourse with her. The complainant eventually escaped and sought help, filing a complaint for rape against the accused-appellant. The complainant was examined at the hospital and a medical certificate indicated the presence of spermatozoa in her vaginal smear. The accused-appellant admitted having sex with the complainant but claimed it was consensual. He was later arrested and detained.

ISSUES:

  1. Whether the accused-appellant committed the crime of rape against the complainant.

  2. Whether the sexual intercourse between the accused-appellant and the complainant was consensual.

RULING:

  1. The court found the accused-appellant guilty of rape. The prosecution presented evidence showing that the accused-appellant forcibly had sexual intercourse with the complainant against her will. The complainant's testimony, supported by the medical certificate and the positive finding of spermatozoa in her vaginal canal, established the commission of rape.

  2. The court rejected the accused-appellant's defense of consensual sex. The court found the complainant's testimony to be more credible. The accused-appellant's claim that the complainant consented to the sexual act was not supported by any evidence.

PRINCIPLES:

  • Rape is committed when a person has carnal knowledge with a woman through force or intimidation and against her will. Consent is an essential element of rape, and the burden of proving consent rests upon the accused. (Doctrine: Elements of Rape)

  • In rape cases, the credibility of the complainant's testimony is of utmost importance. The court must examine the testimony of the complainant with caution, but should not discount it simply because it is uncorroborated. (Doctrine: Credibility of Complainant's Testimony)