Facts:
People of the Philippines charged
Rodolfo dela Cuesta with the rape of
Cristina Gonzales, a
sixteen (16) year old girl, for acts alleged to have occurred “on or about
August 10, 1996 and prior thereto” in
Brgy. Maitim, Municipality of Bay, Province of Laguna, and within the jurisdiction of the trial court. The
Information alleged that the accused was then the
stepfather and guardian of the victim and that, while armed with a bolo, he used
force, violence and intimidation and had
carnal knowledge of the victim “against her will and consent.” Upon arraignment, the accused pleaded
not guilty and proceeded to trial. The victim’s birth certificate showed she was born on
February 14, 1980, sired by a certain
Crispin Gonzales, and that a year after her birth her mother,
Divina Corsanis, became the accused’s
common-law spouse. The evidence for the prosecution established that at about
10:00 in the morning of
August 10, 1996, while the victim was alone at home in
Brgy. Maitim, Bay, Laguna, the accused ordered the victim’s step-brothers and step-sisters to go to the store. When they were left alone, the accused forcibly undressed the victim and kissed her breast. The victim struggled, but the accused then took out a bolo, pointed it at her neck, and warned her not to shout or report the incident because he would kill both her and her mother. He tied her hands behind her back and then sexually assaulted her, ignoring her pleas. After the incident, the victim told her mother, but instead of assisting her in reporting to the Barangay Captain, Divina refused, telling the victim not to report the incident because it would bring imprisonment to their father and would leave the siblings without food. The victim, lacking comfort and support, reported the matter herself to the Barangay Captain and gave her statement at the Municipal Hall of Bay, Laguna. The accused was later arrested after the victim was traced back to Laguna from a hiding place in San Jose, Dasmarinas, Cavite, and entrusted to the
Department of Social Welfare and Development (DSWD) at Alabang. A medical examination conducted by
Dra. Evelyn Macapagal at the Laguna Provincial Hospital on
August 27, 1996 found normal external genitalia, but the physician testified that unlike normal findings where the vagina admits
one finger with difficulty, the victim’s vagina admitted
two fingers with ease, and that this meant her hymen was no longer intact. The accused denied the charge and instead claimed that the complaint was fabricated and instigated by officials connected with
DSWD and
PAG-ASA. He asserted that a PAG-ASA employee,
Susan de Guzman, had a motive due to an alleged misunderstanding over foster care remittances, and he claimed
Rosita Erasga of DSWD instigated the case because of a dispute concerning housing project construction where the accused served as foreman. He also attempted to attack the victim’s character by alleging she had two boyfriends,
Doroteo and
Gary. Divina, the victim’s mother, testified that on the day of the alleged rape, she was at home washing clothes while the accused was allegedly working in Silang, Cavite, and she claimed the victim was absent from school on that day when she attended a
Citizen Army Training (CAT).
Jeffrey dela Cuesta, the victim’s half brother, testified that the victim was in school during that period while the accused was in Dasmarinas, Cavite working.
Noel Calle, a co-worker of the accused, testified that he and the accused worked overtime at Biga, Silang, Cavite on August 10, 1996. Despite these defenses, the trial court found the accused guilty of rape beyond reasonable doubt, sentenced him to
death, and ordered him to pay
P50,000.00 as damages. In
automatic review, the accused insisted, among others, that the medical testimony allegedly had no probative value, that the victim’s testimony was inconsistent with her police sworn statement, that the prosecution was fabricated by DSWD/PAG-ASA officials, and that the victim and accused had been elsewhere at the time, thereby raising reasonable doubt.
Issues:
Whether the accused’s conviction for rape was supported by proof beyond reasonable doubt, and whether the trial court properly imposed the
death penalty and awarded the corresponding damages.
Ruling:
Ratio:
Doctrine: