Title
People vs. Cruz
Case
G.R. No. 201728
Decision Date
Jul 17, 2013
Marvin Cruz's appeal against his rape conviction is denied, as the Court upholds the victim's credible testimony and evidence of force, threat, and intimidation.
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Case Digest (G.R. No. 201728)

Facts:

  • Marvin Cruz was the accused-appellant, and the People of the Philippines were the plaintiff-appellee.
  • The incidents occurred in Brgy. Dulig, Labrador, Pangasinan.
  • Cruz faced two counts of Rape and one count of Violation of Section 5(b) of Republic Act No. 7610.
  • The events took place on October 23, 2007, and November 6, 2007.
  • The victim, referred to as AAA, was a 17-year-old college student who met Cruz through text messaging in March 2007.
  • They became sweethearts but did not meet in person until October 22, 2007.
  • On October 23, 2007, AAA visited Cruz's house, where he allegedly took advantage of her dizziness and forced her into sexual intercourse.
  • On November 6, 2007, Cruz texted AAA, demanding another visit and threatening to circulate a video of their previous encounter.
  • During this second visit, Cruz allegedly forced AAA into sexual acts multiple times using threats and intimidation.
  • Cruz was arraigned on April 17, 2008, and pleaded not guilty.
  • The Regional Trial Court (RTC) found Cruz guilty of two counts of Rape on January 20, 2010, acquitting him of the charge under R.A. No. 7610.
  • The RTC sentenced him to reclusion perpetua and ordered him to pay damages to AAA.
  • Cruz appealed to the Court of Appeals (CA), which affirmed the RTC's ruling on November 28, 2011.

Issue:

  • (Unlock)

Ruling:

  • The Court affirmed Marvin Cruz's conviction for the two counts of Rape, finding the evidence sufficient to establish his guilt beyond reasonable doubt.
  • The Court ruled that the relationship between Cruz and AAA did not imply consent to the sexual acts, and the CA did not err in affirming the RTC's decision.
  • The Court modified the d...(Unlock)

Ratio:

  • The Supreme Court upheld the findings of the RTC and CA, emphasizing the credibility of AAA's consistent and detailed testimony regarding the sexual abuse incidents.
  • The Court noted that a victim of rape is not expected to provide a flawless account of traumatic events, and minor inconsistencies do not undermine overall credibility.
  • Consent cannot be inferred from a romantic relationship, as love does not justify sexual acts against a partner's will.
  • ...continue reading

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