Case Digest (G.R. No. 214886)
Facts:
- The case involves the People of the Philippines as the plaintiff-appellee against Bernie Concepcion, the accused-appellant.
- The events occurred on February 17, 2001, in La Union, Philippines.
- Concepcion was charged with serious illegal detention and two counts of rape.
- The victim, referred to as AAA, lived with her common-law husband in a house owned by Concepcion.
- On the day of the incident, AAA returned home with a sack of rice and was confronted by an intoxicated Concepcion.
- Concepcion threatened AAA with a knife, forcibly dragged her into his room, and locked the door.
- He sexually assaulted AAA twice despite her pleas for mercy.
- Police arrived but Concepcion refused to release AAA until his demands were met.
- Eventually, police officers forcibly entered the room, rescuing AAA, who was taken to the hospital for examination.
- Medical examination revealed injuries consistent with sexual assault.
- The Regional Trial Court (RTC) found Concepcion guilty of forcible abduction with rape, sentencing him to reclusion perpetua and ordering him to pay moral damages to AAA.
- Concepcion appealed, claiming his intent was to extract an admission regarding another alleged rape involving his girlfriend.
- The Court of Appeals modified the RTC's ruling, finding Concepcion guilty solely of rape and increasing the damages awarded to AAA.
Issue:
- (Unlock)
Ruling:
- The Court of Appeals did not err in ruling that the crime of rape absorbed the crime of forcible abduction, as the abduction was committed for the purpose of raping AAA.
- The evidence was sufficient to establish Concepcion's ...(Unlock)
Ratio:
- The Supreme Court upheld the findings of the lower courts, emphasizing that the elements of rape were proven beyond reasonable doubt through AAA's credible testimony, corroborated by medical evidence.
- The Court noted that the forcible abduction was intrinsically linked to the act of rape, as Concepcion's intent was to sexually assault AAA.
- The victim's testimony alone could suffice for a conviction in rape cases, given the intimate nat...continue reading
Case Digest (G.R. No. 214886)
Facts:
The case involves the People of the Philippines as the plaintiff-appellee against Bernie Concepcion, the accused-appellant. The events transpired on February 17, 2001, in La Union, Philippines. Concepcion was charged with serious illegal detention and two counts of rape. The prosecution's narrative indicated that the victim, referred to as AAA, and her common-law husband were living in a house owned by Concepcion, where they contributed to its maintenance. On the day of the incident, AAA returned home with a sack of rice and was intercepted by Concepcion, who was intoxicated. He threatened her with a knife, forcibly dragged her into his room, and locked the door. Concepcion then sexually assaulted AAA twice, despite her pleas for mercy. The situation escalated when police arrived, but Concepcion refused to release AAA until certain demands were met. Eventually, police officers forcibly entered the room, rescuing AAA, who was subsequently taken to the hospital for examination. The medical examination revealed injuries consistent with sexual assault.
In the Regional Trial Court (RTC), Concepcion was found guilty of the complex crime of forcible abduction with rape and sentenced to reclusion perpetua, along with an order to pay moral damages to the victim. Concepcion appealed the decision, arguing that his intent was not to detain AAA but to extract an admission regardi...