Case Digest (G.R. No. 234951)
Facts:
People of the Philippines v. Benjamin A. Elimancil, G.R. No. 234951, January 28, 2019, the Supreme Court Third Division, Peralta, J., writing for the Court.The prosecution (the People of the Philippines) charged accused-appellant Benjamin A. Elimancil with rape under Article 266‑A, paragraph 1 of the Revised Penal Code, alleging that on August 14, 2000, in Mariveles, Bataan, he, by means of force, threat and intimidation and while armed with a bladed weapon, had sexual intercourse with the victim identified in the record as AAA (initials used pursuant to statutory and rule protections for victims).
On the night of August 14, 2000, AAA was alone in her boarding house. She testified that she woke when someone lay beside her and poked a knife into her left side; she recognized the assailant as Benjamin, whom she had known since childhood. AAA narrated that Benjamin pulled down her clothing, removed his own clothing, lay on top of her, forced his penis into her vagina while making push‑and‑pull movements for more than a minute, and that she felt pain and later saw blood; before leaving he threatened her not to tell anyone. She told her boardmate that night and her parents the next day; her father sought police assistance, and the police subsequently located appellant in Mariveles.
On August 17, 2000, AAA was examined by Dr. Neriza A. Paguio at the Bataan Provincial Hospital; the medico‑legal report recorded, among other things, superficial healed lacerations at multiple clock positions on the genitalia. An Information was filed; appellant pleaded not guilty and went to trial. Appellant denied the charge, giving a version that he was invited to a birthday gathering in AAA’s boarding house, slept over, and that other occupants (an adjacent room) would have heard any commotion.
The Regional Trial Court (Presiding Judge Emmanuel A. Silva) found appellant guilty on May 20, 2015, holding that the elements of rape were proven beyond reasonable doubt and noting the aggravating circumstance of use of a bladed weapon; it sentenced appellant to reclusion perpetua without eligibility for parole and ordered payment of P75,000 civil indemnity, P75,000 moral damages, and P30,000 exemplary damages. The Court of Appeals, in CA‑G.R. CR‑HC No. 07588, promulgated July 14, 2017, affirmed the...(Subscriber-Only)
Issues:
- Did the trial court and the Court of Appeals err in finding appellant guilty beyond reasonable doubt of rape based on AAA’s testimony and the medico‑legal findings?
- Should the award of exemplary damages imposed by the trial cou...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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