G.R. No. 139458 - People vs. Cantila, Jr.

The Information charged appellant, Esteban Cantila, Jr., with rape under Article 335 of the Revised Penal Code as amended.
The alleged crime occurred on or about August 25, 1995, at approximately 10:30 p.m. in Patag, Cagayan de Oro City.
Complainant AAA, stated to be 16 years old, was allegedly forced, under threat of violence and the use of a knife, to submit to carnal knowledge against her will.
The charge was based on the premise that appellant employed force, violence, and intimidation during the act.

Complainant AAA was playing a local game (chiki-cha) with the appellant and her employer, Engineer Raul Ramos, at the latter’s residence.
After the game concluded at about 10:30 p.m., the complainant and appellant retired to adjacent rooms separated by only a plywood wall.

The complainant entered her room and noticed a towel and a bottle of rubbing alcohol.
Appellant, already in his room, requested the towel and alcohol and then closed the door.
He then allegedly pulled and pushed the complainant toward his bed while wrapping only a towel around himself.
Using his body and a knife to threaten that he would kill her if she resisted or shouted, he covered her mouth with one hand while using the other to hold the knife.
He reportedly used his foot to remove her shorts and panty, and proceeded with a push-pull movement to forcefully insert his penis into her vagina.

The complainant attempted to fight back by boxing the sides of the appellant's body, though her efforts were described as ineffective.
After the assault, the appellant allegedly ordered her to leave his room.
The following morning, the complainant reported the incident to Engineer Ramos, who then advised her to file a police complaint.
Soon after, she visited the Carmen Police Station and was taken to the Northern Mindanao Hospital, where a medical examination documented four lacerations of her hymen in positions corresponding to the alleged assault.

Medical Specialist Dr. Amado Piit testified that the lacerations on the complainant’s hymen were consistent with sexual intercourse and the timing of the alleged crime.
Engineer Raul Ramos corroborated the complainant’s account by testifying that he was informed of the incident early on August 26, 1995, and that he advised her to seek police assistance.

Editha Cenas, who testified about a pre-existing relationship and familiarity between the appellant and the complainant, indicating that they were seen conversing together on several occasions.
Agueda Cantila, appellant’s mother, testified about an alleged demand for money (P50,000) by a person identified only as Donald, purportedly to keep the complainant from testifying.
Engineer Paquito Palamine testified concerning a prior dalliance when the appellant had introduced the complainant as his girlfriend during a visit.

He admitted to having carnal knowledge of the complainant.
He claimed that the sexual intercourse was consensual and denied any use of force, violence, or intimidation.
He recounted events spanning from early July 1995 up to the incident on August 25, 1995, emphasizing previous interactions which he interpreted as consensual romantic advances, including a proposal and subsequent sexual encounters.

Appellant was arraigned on September 22, 1995, to which he pleaded not guilty regarding the charge of rape.
The trial court, in its decision rendered on May 29, 1998, found the prosecution’s evidence sufficient to establish guilt beyond reasonable doubt.

The court sentenced appellant to suffer reclusion perpetua for the crime of rape.
Additionally, appellant was ordered to indemnify the victim in the sum of P50,000.00 as damages.

That the trial court erred in convicting him of rape beyond reasonable doubt.
That the trial court did not give due weight and credence to the evidence presented in his defense.

Whether the trial court erred in convicting appellant of rape by finding him guilty beyond reasonable doubt despite the contested circumstances regarding the presence or absence of force and resistance.

The dispute centers on whether the complainant’s testimony—which lacked corroborative physical evidence of significant struggle or resistance—meets the high standard of credibility required in rape cases.
Whether the absence of overt physical resistance and other corroborative factors should have led to a reasonable doubt regarding the use of force and intimidation.

Whether the trial court improperly discounted the evidence and testimonies favoring the defense, including the suggestion of prior consensual intimacy between the appellant and the complainant.