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PEOPLE v. EDGAR JUMAWAN

FACTS:

Accused-appellant Edgar Jumawan and his wife, KKK, were married on October 18, 1975, and together they managed several businesses while raising their four children. On February 19, 1999, KKK filed a Complaint-Affidavit alleging that her husband raped her at 3:00 a.m. on December 3, 1998, at their residence in Cagayan de Oro City, and that on December 12, 1998, he physically assaulted her for refusing sex. Consequently, the Office of the City Prosecutor of Cagayan de Oro City found probable cause for grave threats, less serious physical injuries, and rape, leading to the filing of two Informations for rape before the RTC on July 16, 1999. The accused was arraigned and pled not guilty. During the trial, KKK testified that Edgar forced her into sexual intercourse on the nights of October 16 and 17, 1998, by overpowering and intimidating her despite her refusal, citing severe pain and illness. Her daughters, MMM and OOO, substantiated KKK's testimony, recalling her cries for help and their subsequent intervention attempts. In contrast, Edgar presented an alibi claiming he was in Dangcagan, Bukidnon during the alleged incidents and denied the rape charges, suggesting KKK fabricated them out of spite due to business disputes and alleged extra-marital affairs. The RTC found Edgar guilty of both rape charges, giving credence to the victim's straightforward and consistent testimony, corroborated by her daughters' accounts, and dismissing the accused-appellant’s defense of alibi and accusations against KKK. The CA affirmed the RTC's decision in convicting Edgar of two counts of rape, prompting an automatic review by the Supreme Court.

ISSUES:

  1. Whether or not the accused-appellant, Edgar Jumawan, raped his wife, KKK.

RULING:

  1. The Supreme Court found that Edgar Jumawan is guilty of raping his wife KKK on two separate occasions. The court affirmed the decision of the Court of Appeals, which upheld the conviction of the trial court. The court ruled that marital rape exists in the Philippines under Republic Act No. 8353 and the essential element of rape was sufficiently established by the credible testimony of KKK corroborated by her daughters. The penalty of reclusion perpetua for each count was affirmed along with moral, civil, and exemplary damages.

PRINCIPLES:

  1. Marital Rape The Philippines recognizes and penalizes marital rape under Republic Act (R.A.) No. 8353, the Anti-Rape Law of 1997.

  2. Irrevocable Implied Consent Theory The court rejected the notion that a wife gives irrevocable consent to sexual intercourse by virtue of her marriage, emphasizing that rape can occur within marriage.

  3. Force and Intimidation in Rape The force or intimidation employed need not be irresistible but must be sufficient to consummate the purpose the accused had in mind.

  4. Credibility of Witnesses The court gives high regard to the credibility of the testimonies of the victim and corroborating witnesses in rape cases, especially when there is no ill motive for falsity.

  5. Absence of Medical Certificate A medical certificate is not indispensable to prove rape; the victim's credible testimony can be sufficient.

  6. Equal Protection Clause There is no basis to distinguish between marital and non-marital rape cases in terms of legality and the evidentiary standards to prove them.