G.R. No. 207340 - Republic vs. Sandiganbayan, Special 2nd Division

On 21 June 1989, a criminal complaint was filed by fifteen-year-old Mercy Amor Magallanes of Dagupan City, assisted by her mother, Flora Magallanes, before Branch 43 of the Regional Trial Court of Dagupan City.
The complaint charged Ernesto G. Corpuz (also referred to as "Ben") with the complex crime of forcible abduction with rape, alleging that on 19 June 1989 he forcibly abducted Mercy Amor by using a motorized tricycle at gun point under continuous threats.
It was alleged that the accused took the victim to an isolated area in San Miguel, Calasiao, Pangasinan, where he committed carnal knowledge (rape) against her will, in violation of Article 342 in relation to Article 335 of the Revised Penal Code.

The case was docketed as Criminal Case No. D-9395. The accused pleaded not guilty during his arraignment on 16 August 1989, prompting trial on the merits.
The prosecution presented multiple witnesses including:

The offended party, Mercy Amor Magallanes, who testified in detail about the events.
Her mother, Flora Magallanes.
Cpl. Anacleto Andaya, a police officer.
Jose Mejia, the Barangay Captain.
Dr. Rico Reyes, the examining physician, who attested to the medical findings on examination.

The defense presented the accused-appellant as his sole witness, offering testimony that differed markedly from the prosecution’s rendition of events.

Testimonies indicated that at about 10:00 p.m. on 19 June 1989, while walking along A.B. Fernandez Avenue, Mercy Amor was forcibly taken at gun point by the accused, who used threats to compel her into boarding his motorized tricycle.
Upon arrival at a secluded area in San Miguel, Calasiao, the accused began sexually abusing the victim by undressing her, kissing, and forcing her into a degrading position, all while issuing continuous threats, including a direct statement: “You go with me or else I will shoot you.”
The victim’s remonstrations, limited by the threat of death, were corroborated by other witnesses and a medical examination that noted injuries consistent with sexual abuse.

The accused testified that Mercy Amor voluntarily rode in his tricycle, portraying the incident as a consensual act.
He contended that the complainant willingly accepted his sexual proposal and that previous acts of giving money to her on several occasions indicated a paramour relationship.
The defense questioned inconsistencies in her testimony, such as conflicting accounts of her activities prior to the incident, and minimized the significance of her non-resistance during the act.

On 21 June 1991, the trial court rendered a decision finding the accused guilty beyond reasonable doubt of the crime of forcible abduction with rape, sentencing him to reclusion perpetua and ordering him to pay civil indemnity of ₱50,000 to Mercy Amor Magallanes.
In reaching its decision, the trial court upheld the credibility of the victim’s testimony, dismissing the defense’s version as “incredible” and unsubstantiated by corroborative evidence.
The accused-Appellant appealed the decision on the grounds that:

The trial court erred in anchoring its verdict on what he argued were dubious conclusions regarding the use of force and intimidation.
The evidence did not conclusively prove that the rape was committed without the complainant’s consent.
The inconsistencies in the victim’s narrative and the alleged absence of a firearm (instead noting only “the handle of the motorcycle”) should have led to an acquittal.

His evidence of a voluntary act was disregarded unfairly by the trial court.
Testimonies and minor inconsistencies about the victim’s whereabouts did not substantiate the allegation of forcible abduction with rape.

The cumulative evidence clearly demonstrated that the victim was coerced through credible threats, establishing the non-consent required for rape.
The victim’s consistent, categorical testimony—and her willingness to endure public humiliation and medical examination—underscored the veracity of her account.
Minor discrepancies in her statements were de minimis and did not detract from the overall reliability of the evidence against the accused-appellant.

Whether the trial court erred in convicting the accused-appellant of forcible abduction with rape by:

Relying on the victim’s testimony which detailed that she was taken under threat of death, despite minor inconsistencies in her account.
Dismissing the accused’s evidence that contended the alleged act was consensual.

Whether the trial court improperly interpreted the element of force or intimidation:

Specifically, whether the threat “you go with me or else I will shoot you” sufficed to establish that the victim’s consent was negated.
Whether the absence of an actual firearm diminishes the credibility of the prosecution’s claim of coercion.

Whether the trial court correctly evaluated the alleged mental state of the victim:

The issue of whether evidence or mere insinuations regarding the victim’s alleged mental retardation should have affected the assessment of her testimony and credibility.
Whether her ability to give detailed and consistent testimony refuted claims of incapacity.