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PEOPLE v. BERNIE CONCEPCION

FACTS:

Accused-appellant Bernie Concepcion was charged with serious illegal detention and two counts of rape. During the trial, the prosecution presented AAA's version of events, stating that Concepcion kidnapped and detained her, and had non-consensual sexual intercourse with her. Chief of Police Pedro Obaldo, Jr. and other individuals were called to the scene, and eventually, the police broke into Concepcion's room and rescued AAA. Concepcion did not present any evidence during the trial.

In its decision, the Regional Trial Court found Concepcion guilty of the complex crime of forcible abduction with rape but dismissed one charge of rape due to lack of evidence. The Court of Appeals affirmed the conviction but ruled that the crime of rape absorbed the crime of forcible abduction. The Court of Appeals imposed the penalty of reclusion perpetua and ordered Concepcion to pay damages to the victim.

Concepcion appealed the decision to the Court of Appeals, arguing that there was no evidence to show his intent to detain or abduct AAA. He also contested the evidence of rape, citing the absence of certain evidence. The Court of Appeals denied Concepcion's appeal, holding that the elements of rape and abduction were proven beyond reasonable doubt. It ruled that the forcible abduction of AAA was for the purpose of raping her, and therefore, the crime of rape absorbed the forcible abduction. The Court of Appeals also increased the amount of damages awarded.

Concepcion filed a Notice of Appeal with the Court of Appeals, and the case was elevated to the Supreme Court. The Supreme Court required the parties to submit their respective supplemental briefs.

ISSUES:

  1. Whether accused-appellant should be acquitted of the second count of rape.

  2. Whether accused-appellant should be convicted for the first count of rape.

  3. Whether the testimonies of the victim are credible.

  4. Whether the charge of serious illegal detention is absorbed in the crime of rape.

  5. Whether accused-appellant is guilty of the crime of rape.

  6. Whether accused-appellant is guilty of the crime of slight illegal detention.

RULING:

  1. Accused-appellant should be acquitted of the second count of rape due to the failure of the prosecution to establish beyond reasonable doubt that it actually happened.

  2. Accused-appellant should be convicted for the first count of rape. The Court of Appeals and the Regional Trial Court found the testimony of the victim to be credible and convincing. The victim's testimony, together with the corroborating evidence from the medical examination, sufficiently established beyond reasonable doubt that the rape was committed.

  3. The testimonies of the victim are credible. The Court of Appeals found that the victim's testimonies on both incidents of rape were equally credible. The judge who examined the victim also found her a believable witness. The evidence was sufficient to establish the accused's guilt of the second rape charge.

  4. The charge of serious illegal detention is not absorbed in the crime of rape. Although the initial abduction of the victim may have been absorbed by the crime of rape, the continued detention of the victim after the rape cannot be deemed absorbed in it. The facts show that after raping the victim, the accused continued to detain her and refused to release her. Thus, the accused is also guilty of the crime of serious illegal detention.

  5. Accused-appellant is found guilty beyond reasonable doubt of two counts of the crime of rape. He is sentenced to suffer the penalty of reclusion perpetua for each count.

  6. Accused-appellant is found guilty beyond reasonable doubt of the crime of slight illegal detention. He is sentenced to suffer an indeterminate penalty of imprisonment from nine years and four months of prision mayor as minimum to sixteen years and five months of reclusion temporal as maximum.

PRINCIPLES:

  • In a prosecution for rape, the credibility of the victim's testimony is of utmost importance. The testimony of a single witness, if credible, may be sufficient to convict the accused. Corroboration of the victim's testimony is not required by law. (citing settled jurisprudence)

  • Rape can be proven through the testimony of the victim if it is credible, convincing, and consistent with human nature and the normal course of things. The absence of witnesses to the rape does not undermine the credibility of the victim's testimony.

  • In rape cases, the credibility of the victim's testimony is of primordial consideration.

  • The initial abduction may be absorbed by the crime of rape, but the continued detention after the rape cannot be deemed absorbed in it.

  • The elements of slight illegal detention are: (1) the offender is a private individual; (2) he kidnaps or detains another, or in any other manner deprives him of his liberty; (3) the act of kidnapping or detention is illegal; and (4) the crime is committed without the attendance of any of the circumstances enumerated in Art. 267.

  • Current jurisprudence awards P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P75,000.00 as exemplary damages for each count of rape.

  • The award of damages shall earn interest at the rate of six percent (6%) per annum from the date of the finality of the judgment until fully paid.