FACTS:

The case involves the rape committed by the accused-appellant Sonny Ramos against the victim, referred to as AAA. Both Ramos and AAA were employees of a hotel in Baguio City and resided in the hotel compound. On December 27, 2007, AAA went to the hotel recreation room to watch television but decided not to proceed upon seeing Ramos taking the remote control from the office. AAA later returned to the quarters and encountered Ramos leaving the recreation room. Ramos approached AAA and expressed his intention to watch television together. When AAA tried to leave, Ramos blocked her way. He then forcibly carried her to the bed, removed her bra and pants, and sexually assaulted her. Despite AAA's resistance, she eventually succumbed to Ramos' strength. After Ramos left the room and went to the bathroom, AAA took the opportunity to escape and later reported the incident to her friend and brother-in-law. She underwent a medical examination that revealed lacerations on her hymen, consistent with sexual assault. Ramos denied the rape charge and alleged that AAA voluntarily undressed during the incident.

Subsequently, Ramos was convicted of rape, with AAA's testimony as the primary basis for his conviction. Ramos argued that the sexual activities were consensual, claiming that he and AAA were lovers and that they had previously engaged in consensual sexual intercourse. AAA reported the rape to various individuals, including her friends, family, the hotel owner, and the police, leading to Ramos' arrest. The trial court found Ramos guilty and imposed the penalty of reclusion perpetua. Dissatisfied, Ramos appealed to the Court of Appeals (CA), which upheld the trial court's decision. Ramos then filed a Notice of Appeal before the Supreme Court, raising the sufficiency of evidence to prove his guilt beyond reasonable doubt as his main contention.

ISSUES:

1. Whether or not Ramos is guilty beyond reasonable doubt of the crime of Rape.

2. Whether the failure of the victim to scream or resist negates the commission of rape.

3. Whether the victim's conduct before and after the rape detraction from her credibility.

4. Whether the presentation of the SIM card as evidence was properly denied by the court.

5. Whether the penalties imposed by the trial court were correct.

6. Whether the awards for civil indemnity, moral damages, and exemplary damages were appropriate.

RULING:

1. The instant appeal is bereft of merit. The prosecution established beyond reasonable doubt that Ramos is guilty of rape. The court held that the prosecution sufficiently established that Ramos had carnal knowledge with the victim through force and intimidation, against her will and without her consent. The court also emphasized that the absence of bodily injury does not negate the commission of rape, and that resistance is not an element of rape.

2. The failure of the victim to scream or resist does not disprove the commission of rape. The lack of resistance does not imply that the victim consented to the sexual act, especially when she was intimidated into submission by the perpetrator.

3. The victim's conduct before and after the rape does not detract from her credibility. The reactions and behavior of rape victims vary, and it is unfair to expect a rational reaction or standard behavior from them. The fear of the victim due to the perpetrator's threat and the victim's need to earn a living should not be used against her.

4. The Court found that the claim of the accused that he was deprived of presenting the SIM card as evidence was unsubstantiated. The accused's counsel manifested his inability to present the evidence, thereby waiving the opportunity to do so. Thus, the denial of the presentation of the SIM card as evidence was proper.

5. The crime of simple rape is penalized with reclusion perpetua. Since the guilt of the accused was proven beyond reasonable doubt, the trial court correctly imposed the penalty of reclusion perpetua.

6. In rape cases, an award of civil indemnity, moral damages, and exemplary damages is justified. The trial court initially awarded civil indemnity and moral damages in the amount of Php 50,000.00 each. However, the Supreme Court increased these amounts to Php 75,000.00 each, in accordance with prevailing jurisprudence. Additionally, the court granted an award of exemplary damages amounting to Php 75,000.00. All amounts due shall earn legal interest of six percent (6%) per annum from the date of the finality of the decision until full payment.

PRINCIPLES:

• Rape is committed when a man has carnal knowledge of a woman through force or intimidation, when the victim is deprived of reason or otherwise unconscious, by means of fraudulent machination or grave abuse of authority, or when the victim is under 12 years of age or is demented.

• To sustain a conviction for rape, the prosecution must prove that the accused had carnal knowledge of the victim and that the act was accomplished through force or intimidation, when the victim is deprived of reason or otherwise unconscious, by means of fraudulent machination or grave abuse of authority, or when the victim is under 12 years of age or is demented.

• Absence of bodily injury and the victim's failure to scream or flee do not prove consent to the sexual act. The force used in the commission of rape need not be overpowering or absolutely irresistible. Resistance is not an element of rape.

• The failure of the victim to scream or resist does not negate the commission of rape.

• The lack of resistance does not imply that the victim consented to the sexual act, especially when she was intimidated into submission.

• The reactions and behavior of rape victims may vary, and it is unfair to expect a rational reaction or standard behavior from them.

• Fear and threats may prevent a rape victim from immediately reporting the incident.

• The need to earn a living may also affect a rape victim's decision to continue working in an environment where the perpetrator is present.

• Once the fact of rape is duly established, moral damages are awarded to the victim without the need for further proof, recognizing that the victim suffered moral injuries from the ordeal.

• Civil indemnity is awarded as a form of monetary restitution or compensation for the damage or infraction inflicted by the accused.

• Exemplary damages are awarded to punish the offender for their outrageous conduct and to deter the commission of similar acts in the future.

• The penalties for offenses are determined by law, and the court must appropriately impose the penalties based on the established evidence.

• The court may increase the amounts of civil indemnity, moral damages, and exemplary damages in accordance with prevailing jurisprudence.