Case Digest (G.R. No. L-37798)
Facts:
The case involves Ramon Dadaeg, a teacher at the Community School in Roxas, Palawan, who was accused of raping Teofila Dangan, a 13-year-old student. The incident occurred on April 14, 1966, when Dadaeg dismissed his grade six class during recess after conducting a periodical test. He asked Teofila to stay behind to help him correct the test papers and persuaded her to go to his father's house for this purpose. Once there, Dadaeg allegedly dragged Teofila into the bushes, overpowered her despite her struggles, and threatened her with a knife to silence her. He then stripped her and attempted to have sexual intercourse with her, ultimately succeeding in having carnal knowledge of her. An eyewitness, Benjamin Bagona, observed the incident from a nearby tree. After the assault, Teofila ran home crying and initially remained silent due to threats from Dadaeg. Eventually, she confided in her parents, leading to her medical examination at Puerto Princesa Hospital on April 20, 1...
Case Digest (G.R. No. L-37798)
Facts:
The case involves Ramon Dadaeg, a teacher at the Community School in Roxas, Palawan, who was found guilty of the crime of rape. The complainant, Teofila Dangan, was a 13-year-old student. On April 14, 1966, during the recess period, Dadaeg dismissed his grade six class after reviewing the periodical test. Teofila Dangan and another pupil, Perlita Sibuya, were homeward bound when Dadaeg asked Teofila to stay to help in the correction of the test papers. They proceeded to the house of Dadaeg's father, where Teofila was left alone with him. Dadaeg suddenly grabbed her, dragged her towards the bushes, and overpowered her despite her struggles. He stripped her of her garments and raped her. There was an eyewitness, Benjamin Bagona, who saw the incident from a nearby tree. After the incident, Teofila ran home crying and remained silent for a few days due to threats. Later, she confessed to her parents and was brought to the Puerto Princesa Hospital for a medical examination by Dr. Natividad Martin. The medical examination revealed that the hymen was ruptured, with old lacerations.
The defense presented an alibi, claiming that Dadaeg did not leave the schoolhouse during the time of the incident, corroborated by one of his pupils, Erlinda Cacatian. The trial court judged the defense of alibi as weak and disregarded it. Appellant was sentenced to reclusion perpetua plus indemnification to the offended party in the amount of P12,000.00.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- The trial court was correct in giving credence to the testimony of Teofila Dangan. Her testimony was clear, straightforward, and corroborated by an eyewitness, Benjamin Bagona.
- The defense of alibi was weak and lacked persuasiveness. The trial court correctly disregarded it.
- The absence of sperm and the old ruptures of the hymen are not essential to the consummation of rape. As long as there is penetration, rape is consummated.
- The appellant should not be acquitted on grounds of reasonable doubt, as the evidence proved guilt beyond reasonable doubt.
- The court found that the hymen's rupture, as testified by the examining physician, Dr. Natividad Martin, was old, but this does not negate the occurrence of rape.
Facts:
The defendant, Ramon Dadaeg, was convicted of rape and sentenced to reclusion perpetua plus an indemnification of P12,000.00 to the complainant, Teofila Dangan. The incident occurred on April 14, 1966, when Dadaeg, a teacher at the Community School in Roxas, Palawan, dismissed his grade six class during the recess period. He asked Teofila, a 13-year-old student, to stay to help correct test papers. While she was alone with him, he allegedly overpowered and raped her. An eyewitness, Benjamin Bagona, saw the incident from a nearby tree. After the incident, Teofila remained silent for a few days due to threats but eventually confessed to her parents. She was medically examined by Dr. Natividad Martin, who found that her hymen was ruptured, with old lacerations.
The defense presented an alibi, supported by testimony from one of Dadaeg’s pupils, Erlinda Cacatian, who claimed that both the accused and Teofila were in school during the incident. The trial court dismissed the alibi as weak and improperly corroborated.
Issue:
- Whether the trial court erred in giving credence to the testimony of Teofila Dangan despite alleged inconsistencies and contradictions.
- Whether the trial court erred in not giving credit to the defense’s evidence, including the absence of sperm and the old ruptures of the hymen.
- Whether the trial court erred in not acquitting the accused on grounds of reasonable doubt and insufficiency of evidence.
Ruling:
The Supreme Court affirmed the trial court’s decision but modified the indemnification to P30,000.00. The Court held that appellant Ramon Dadaeg was guilty beyond reasonable doubt of the crime of rape.
Ratio:
The trial court was correct in giving credence to Teofila Dangan's testimony, which was corroborated by an eyewitness, Benjamin Bagona. Her testimony was clear, straightforward, and relayed with spontaneity and natural demeanor.
The defense of alibi lacked persuasiveness and failed to meet the standard required for such a defense to prosper. The corroborative testimony of Erlinda Cacatian was of doubtful credibility.
The absence of sperm and the old ruptures of the hymen are not essential to prove rape. Penetration of the female organ by the male organ, regardless of the hymen’s condition, is sufficient to consummate rape.
The appellant should not be acquitted on grounds of reasonable doubt, as the evidence proved his guilt beyond reasonable doubt.
The trial court correctly considered the medical examination of Teofila Dangan, despite the absence of testimony from Dr. Natividad Martin, as the hospital records and other medical evidence were sufficient.