G.R. No. 98431 - People vs. Dela Torre

On November 5, 1989, in the Municipality of Teresa, Rizal, the accused, Josue Dela Torre, allegedly committed the crime of rape against Marita Cordova.
The incident occurred at the La Fiesta Farm where Marita worked as a cook and where both her husband, Paulino Cordova, and the accused were employed.

Around 7:00–8:00 P.M., a disturbance at the farm led Paulino Cordova to seek help from nearby farm resident Anthony Inocencio, due to the accused causing commotion while armed with a knife and bolo.
After arriving at the farm, Anthony learned that the accused had taken money and shoes from the workers, after which Marita and her children were allowed to seek refuge at his farm.
At approximately 8:00 P.M., while Marita was cooking in the kitchen with her five children, the accused appeared armed, forcibly dragged her outside, and led her to a nearby house under construction.
As they moved toward the house, various farm workers, including Joel Villasis and Johnny Dizon, observed the accused brandishing his knife and bolo but did not intervene due to fear.

Inside the under-construction house, the accused pinned Marita to the ground by force:

He threatened her by holding a knife to her throat and used the bolo for additional intimidation.
He lifted her dress above her breast and forcibly removed her panty.
Despite the victims’ attempts to resist, Marita was overpowered by the physical threat posed by the weapon.

The accused proceeded to kiss, caress, and ultimately insert his penis into her vagina for approximately eight to ten minutes, all while keeping the knife pointed at her.
After the assault, he threatened further violence by indicating that he would slash her neck if she disclosed the crime.
The victim later reported the incident, first to Anthony Inocencio, then to her employer and husband.

Marita Cordova, who provided a detailed account of the rape with specific emphasis on the use of the knife and bolo, and the dynamics of the assault.
Melanie Cordova, Marita’s 10-year-old daughter, who confirmed seeing her mother being dragged and threatened with a knife and bolo from the relative proximity of the kitchen.
Anthony Inocencio, who testified regarding the actions of both Paulino Cordova and the accused during the commotion at the farm.

Established that Marita sustained physical injuries (abrasions on the finger and leg) consistent with the violent encounter.
Noted that physical findings corroborated the non-virgin state of the victim, as well as injuries that would take several days to heal, lending credibility to her testimony.

The accused admitted to having had sexual contact with Marita on the night in question.
He contended that the encounter was consensual, asserting that Marita was his mistress; he detailed:

Their alleged romantic involvement beginning on June 15, 1987, in Bacolod City during a social gathering in a Cordova residence.
A history of frequent sexual encounters leading up to, and resuming in, October 1989 at the La Fiesta Farm.
An alternate timeline where an appointment was set for 8:00 P.M. at the house under construction following a conversation in the farm’s kitchen, where consensual intercourse purportedly occurred on a mat (asawalia) on the ground.

Whether the evidence presented by the prosecution, including the testimonies of Marita, Melanie, and Anthony Inocencio, established the crime of rape beyond a reasonable doubt.
Whether the physical and forensic evidence, such as the Medico-Legal Report findings, corroborated the victim’s account of force and intimidation.

Whether the accused’s claim that the sexual encounter was consensual—stemming from an alleged prior intimate relationship with Marita—could be substantiated in light of the circumstances of the assault.
Whether the defense’s “sweetheart theory” was supported by any corroborative evidence beyond the accused’s bare assertion.

Whether the location of the incident, specifically the use of the kitchen (regarded as the victim’s adwelling), qualifies as an aggravating circumstance under the legal standard.
How this aggravating circumstance affects the imposition of the penalty, given the statutory guidelines and the subsequent application of reclusion perpetua (with death penalty suspended).

Whether the trial court erred in its conclusion and conviction of the accused beyond reasonable doubt.
Whether the decision on the civil aspect, particularly the award of civil indemnity and damages, was properly rendered given the evidence of criminal perversity and aggravation.