G.R. No. 242690 - People vs. Fruelda y Anulao

Wodie Fruelda y Anulao (Accused-Appellant) was charged with the crime of rape under Article 266-A, paragraph 1(b) of the Revised Penal Code for an incident allegedly occurring on April 28, 2014, at around 8:00 A.M. at Barangay Kumintang Ibaba, Batangas City.
The Information accused Fruelda of forcibly and unlawfully inserting his fingers into the genital organ of AAA (the Private Complainant) and thereafter having carnal knowledge of her while she was unconscious and against her will.
Fruelda pleaded not guilty; trial ensued after pre-trial.

The Private Complainant (AAA), a full-time worker of Jesus the Anointed One Church, testified she was asked by Fruelda (driver of Bishop Arthur Gonzales) to retrieve bar soaps from the church storeroom.
Inside the storeroom, after explaining the inventory situation, Fruelda suddenly grabbed her breasts causing pain and shock.
Despite AAA's resistance and shouting, Fruelda groped her genital area over her pants, dragged her inside the bodega, blocked the door, fondled her, unzipped her pants, and inserted his fingers into her vagina.
The Complainant protected herself by crossing her arms in an "X" but sustained bruises; Fruelda pressed her onto a wall, causing a head bump and disorientation.
After Fruelda pulled out his penis and said "tumuwad ka" ("bend over"), AAA lost consciousness and later found herself on the floor with her pants and underwear pulled down to her knees. Fruelda was gone.
AAA sought help from fellow church members who accompanied her to police stations for filing of the complaint and medical examination, which showed physical injuries and trauma.

Edna Rabano Ilagan: corroborated AAA’s emotional state and immediate assistance after the incident.
Police Inspector Julieta Magpantay: testified regarding complaint intake, observation of bruises, ocular inspection of the scene, and investigation.
Dr. Jerico Cordero (Medico-Legal Officer): interpreted the medical report showing fresh hymenal lacerations and multiple abrasions consistent with forceful trauma.

Fruelda denied the rape allegations and claimed a consensual sexual relationship ("sweetheart theory") with AAA.
He testified that on the morning of April 28, 2014, they engaged in sexual acts consensually inside the storeroom and that after, he delivered soaps to a fellow member and left to drive the Bishop.
Fruelda voluntarily surrendered to the police after learning of the complaint.
Conchita Pandi and Romel Elida, co-members of the church, testified seeing Fruelda and AAA together and behaving familiarly; Pandi contradicted the allegation that AAA was locked inside the storeroom.

The RTC found Fruelda guilty beyond reasonable doubt of rape, sentencing him to reclusion perpetua and ordering indemnities to the victim.
The court rejected the sweetheart theory citing lack of independent evidence to establish a consensual relationship and relied heavily on the medico-legal report and physical evidence of struggle.
The court emphasized the credibility of the victim’s detailed and consistent testimony and the injuries shown by photographs and medical findings.

The CA affirmed the RTC decision with modification, increasing damages awarded to the victim.
It rejected Fruelda’s assertions of consensual relations due to lack of compelling evidence such as tokens or love notes to prove the sweetheart defense.
The CA also ruled that the mitigating circumstance of voluntary surrender was not applicable since Fruelda lacked intent to surrender unconditionally.

The Supreme Court noted the Information charged Fruelda with both sexual assault and rape by carnal knowledge but he did not object to the dual charges before trial.
The Court stressed the need to scrutinize complainant's testimony with caution but also affirmed the credibility and consistency of AAA’s account.
The Court examined the testimonies and medical evidence in depth, highlighting the presence of fresh hymenal lacerations, multiple bruises, and evidence of blunt trauma likely caused by a finger.
Fruelda admitted to inserting his finger into AAA's genitalia consensually per his sweetheart theory, but the Court found the evidence lacking to prove any consent or romantic relationship.
On the basis of the victim’s testimony and medico-legal findings, the Court concluded that Fruelda was guilty of sexual assault under Article 266-A(2), not rape by carnal knowledge under Article 266-A(1)(b).
The Court ruled that while possible carnal knowledge occurred, the prosecution failed to establish it beyond reasonable doubt.
The Court found merit in Fruelda’s voluntary surrender and applied it as a mitigating circumstance.
Fruelda was sentenced to the indeterminate penalty of imprisonment from six (6) years and one (1) day to eight (8) years, and ordered to pay civil, moral, and exemplary damages amounting to Thirty Thousand Pesos (₱30,000.00) each with legal interest.

Whether the Court of Appeals erred in finding the accused guilty beyond reasonable doubt of rape by carnal knowledge.
Whether the mitigating circumstance of voluntary surrender is applicable in favor of the accused.