Case Digest (G.R. No. 94545)
Facts:
People of the Philippines appealed the Court of First Instance of Baguio and Benguet’s judgment convicting Eduardo de Dios y Exconde of rape and sentencing him to reclusion perpetua, with damages and attorney’s fees, after Concepcion Guanzon testified that he dragged and forced her inside a room in his Baguio City residence on 22 March 1973 and continued to assault her despite resistance. The accused presented love letters and witnesses who claimed the complainant looked affectionate with him and had no visible injuries, while he did not testify.The complainant reported the incident immediately to the police, was examined at the Baguio City General Hospital, and sustained multiple hematomas and a vaginal laceration, and she denied consent, explaining her fear, confusion, and threats from the accused. The defense argued that the complainant’s testimony contained inconsistencies and should be disregarded, and that the trial court allegedly failed to credit her claim of forcible
Case Digest (G.R. No. 94545)
Facts:
- Parties and relationship
- People of the Philippines prosecuted Eduardo de Dios y Exconde (defendant-appellant) for rape.
- The complainant, Concepcion Guanzon (then twenty four (24) years old), and the accused were sweethearts.
- In the latter part of 1972, the complainant was “very much in love” with Eddie and sent many affectionate letters, sometimes three (3) a day.
- The complainant wrote one letter stating only “I love you” twenty-nine (29) times.
- The complainant’s love did not diminish after she learned that the accused had contracted marriage with Venus Joy Mesina, because she was assured that the marriage would be annulled.
- Events immediately prior to the incident (annulment papers and hospital chapel)
- Shortly before noon of 22 March 1973, the complainant was attending to her mother, who was confined at Makati Medical Center.
- The accused and his mother visited and brought papers granting the petition to annul the accused’s marriage to Venus Joy.
- While the complainant’s mother read the papers, the accused and the complainant slipped out unnoticed.
- They went to the hospital chapel to say prayers.
- The complainant guided the accused in a tour of the hospital premises.
- At the hospital lobby, the complainant decided to go back to her mother.
- The accused chided her and told her they should go up, but the complainant insisted on returning because her mother was alone.
- The accused said they would fetch his sister Cecille from Assumption College, a few city blocks from the hospital.
- The complainant demurred because she was not properly attired and was only wearing slippers.
- The accused insisted and prevailed.
- They boarded their Kombi; at the accused’s summons, the driver was told “Kay Cecille.”
- They did not go to Cecille; instead, the complainant was brought to Baguio City.
- Journey and arrival at accused’s house (22 March 1973)
- They stopped for a while at Jojo’s restaurant in San Fernando, Pampanga.
- They arrived at the accused’s house at 96 Kennon Road, Baguio City, at about 6:00 p.m. on 22 March 1973.
- After getting the house keys from the caretaker, the accused gave money to the driver to buy food.
- After taking supper, the accused invited the complainant to rest in a room.
- The complainant refused and preferred to stay in the sala.
- The accused held her by the arm, dragged her into a room, and attempted to force himself upon her.
- The complainant pleaded and begged the accused to desist because they were getting married, but the accused ignored her entreaties and continued forcing himself.
- The rape in the adjoining rooms (complainant’s detailed narration)
- Around 8:00 p.m., the accused told her to “Matulog ka na sa isang cuarto,” but she refused to sleep there.
- The accused dragged her into one of two adjoining rooms with a common toilet.
- A struggle began: the accused tried to embrace and kiss her, and he attempted to hold her breast while they stood.
- The accused would tire, sit on the bed, and then continue the assault.
- The complainant warded off the accused by pushing him away, holding his hand, and fighting him with one hand while holding her pants with the other.
- During a renewed struggle, the accused tried again to drag her into the bed, but the complainant succeeded in warding him off at that time.
- The complainant then took an occasion when the accused rested, jumped out of bed, went to the toilet, and locked herself inside.
- The accused ran immediately, but the door knob fell; the accused placed it back again and the struggle resumed.
- The complainant was then pinned down with the accused’s full weight sideways.
- The accused pressed his forearm against her neck and fumbled with her bra at the back; he failed to remove the bra because the snap was in front.
- The accused concentrated on removing her pants but intermittently failed because he would rest, catch his breath, and then resume.
- Around 2:00 or 3:00 a.m., the accused appeared to lie beside her, breathing heavily then softly, and the complainant knew he had fallen asleep.
- The complainant transferred to the other room and locked herself, including the door to the toilet leading to the other room, and also locked the corridor door.
- She could not sleep; she was fully awake, confused, and fearful of what would happen if she disappeared.
- After she dozed briefly, she saw the accused beside her again and the struggle started anew.
- Around 5:00 or 6:00 (she stated March 23), the accused fumbled her pants again through the corridor using a key he had.
- The accused pinned her down; he pressed his forearm against her neck and fumbled her bra.
- He still failed to remove her bra and could not remove her shirt.
- The accused finally succeeded in removing her pants and panty; the complainant began to weaken after about thirty (30) minutes due to the struggle, lack of food, and lack of sleep.
- The struggle continued on the bed, and the accused tried to part her legs.
- The accused started giving her fist blows so her legs would part.
- The accused stretched her legs apart, planted his knees between them, and half-strangled her, holding her neck.
- The accused guided his penis inside her; she felt a stabbing pain, after which the accused’s movement stopped for a few seconds.
- The complainant lay exhausted, mentally “black,” and did not know what to do.
- Attempts after the first assault (23 March 1973)
- After taking supper on the evening of 23 March 1973, the accused tried again to make love to the complainant.
- The complainant refused, pleaded to be left alone, and the accused acceded, allowing her to sleep in the other bedroom.
- The next morning, the accused entered her bedroom and again tried to force himself.
- The accused did not succeed because she resisted and locked herself in the bathroom.
- The accused forced open the bathroom door, and the complainant ran to the sala.
- The accused followed her, but was interrupted by a knock at the door.
- Telephone call to mother and instruction about where they would go
- The accused answered the knock and later told the complainant to accompany him to a neighbor’s house.
- The accused placed a telephone call to his mother but failed to contact her.
- The accused instructed the neighbor that if the mother called, they would be on their way to Quezon City.
- Second forced incident interrupted by sister’s arrival
- They returned to the accused’s house at 96 Kennon Road.
- Seated in the sala, the driver knocked and told the accused that he had a visitor.
- The accused ordered the complainant inside the bedroom.
- When the complainant refused, the accused dragged her into the room and closed the door.
- Soon the complainant heard someone calling her by name.
- She recognized the voice as that of her sister, Mrs. Rosalinda Antiporda.
- The complainant went out, embraced her sister, and cried: “Ate Inday, pinuwersa niya ako. Ilayo mo na ako agad.”
- The sister told the complainant that their mother instructed her to determine whether the complainant had gone with the accused of her own free will; if she had, the sister should ensure that they were properly married; if not, she should bring the complainant home.
- The complainant told her sister: “Pinuwersa niya ako. Ilayo mo na ako agad.”
- Reporting and medical findings
- The incident was immediately reported to the Baguio City Police Department.
- The complainant was brought to Baguio City General Hospital...(Subscriber-Only)
Issues:
- Credibility and sufficiency of evidence
- Whether the trial court erred in crediting the complainant’s testimony that she was raped, despite alleged inconsistencies and defects pointed out by the accused.
- Whether the evidence presented by the prosecution was sufficient to prove guilt beyond reasonable doubt.
- Alleged misapplication of evidentiary rules on testimony
- Whether the trial court should have disregard