G.R. No. 183094 - People vs. Barde

Accused-appellant Marvin Cayanan was charged before the Regional Trial Court (RTC) of Malolos City, Bulacan, Branch 77, with the crimes of Qualified Rape (Criminal Case No. 1499-M-2001) and Forcible Abduction with Qualified Rape (Criminal Case No. 1498-M-2001).
The RTC convicted Cayanan of both crimes, sentencing him to reclusion perpetua without eligibility for parole for each offense and awarding damages to the victim.
The victim, identified by fictitious initials AAA to protect her identity, was 15 years old at the time of the offenses.

On February 1, 2001, Cayanan, who was the victim’s brother-in-law, took advantage of AAA inside her house in Bulacan. AAA was asleep when Cayanan touched and forcibly kissed her, removing her shorts against her will and then sexually assaulting her while threatening to kill her if she resisted or told anyone.
On February 26, 2001, at the school campus gate, Cayanan pulled AAA forcibly towards a tricycle and covered her mouth when she tried to shout for help. He then took her to various places, including a dress shop and a Jollibee outlet, before bringing her to his sister’s house where he raped her again inside a bedroom.
After the incident, the victim was brought to the barangay office to sign a document stating she voluntarily went with Cayanan. She was later brought home by Cayanan’s mother and sister-in-law.
AAA only informed her family about the incidents after a classmate, Adriano, told her family of the rape. AAA testified that she was still in shock and thus delayed reporting the crimes.

AAA’s testimony was corroborated by her classmate Adriano and her mother.
A psychiatrist from the National Center for Mental Health testified that AAA was suffering from symptoms consistent with sexual abuse and mental depression.
Cayanan presented a “sweetheart defense,” alleging a consensual relationship with the victim, supported only by two love letters supposedly written by AAA.
Both the RTC and the Court of Appeals (CA) found the love letters to be unauthenticated and gave them no probative value.

Increased civil indemnity for both criminal cases from P50,000 to P75,000.
Increased moral damages in Criminal Case No. 1498-M-2001 from P50,000 to P75,000.
Additional moral damages of P75,000 in Criminal Case No. 1499-M-2001.
Exemplary damages of P30,000 awarded in both cases.

Upon review, the Supreme Court found that forcible abduction was absorbed in the crime of rape in Criminal Case No. 1498-M-2001, modifying the conviction to only Qualified Rape.
The CA’s award of damages and rejection of the sweetheart defense were upheld.
Interest at six percent per annum was ordered on all damages from the date of finality until fully paid.

Whether or not accused-appellant Marvin Cayanan is guilty of Qualified Rape and Forcible Abduction with Qualified Rape.
Whether the sweetheart defense presented by the accused-appellant should be given credence despite the testimonies and evidence presented by the prosecution.
Whether the awards for civil indemnity, moral, and exemplary damages granted by the CA are proper and supported by law and jurisprudence.
Whether forcible abduction should be considered a separate crime or absorbed in the crime of rape under the facts of the case.