G.R. No. 74047 - People vs. Geneveza y Evangelista

The case is an appeal from the decision of the Regional Trial Court of Malabon, Metro Manila, in Criminal Case No. 069-MN.
The trial court had convicted Graciano Geneveza of rape and sentenced him to reclusion perpetua.
The incident occurred on March 18, 1982, at around 8:00 p.m. in Malabon, Metro Manila.

Complainant Nenita Obogne, a resident of Bagong Barrio, Caloocan City (previously from Riverside, Potrero, Malabon), was walking along Dona Juana Road after visiting Dr. Erlinda de la Cruz.
The accused, Graciano Geneveza, allegedly used a knife wrapped in a newspaper to intimidate her.
He forced her into a house belonging to Melanio Antipuesto, located at the back of the Cosmos Bottling Company.
Once inside, after she refused to remove her clothing, Geneveza forcibly removed her garments and placed himself on top of her, engaging in sexual intercourse twice.
After the acts, he instructed her to dress, and they exited the house at around 6:00 o’clock in the morning without any further communication.

Nenita stated that she did not know Geneveza prior to the incident.
She admitted to not shouting or struggling because she was too afraid, allegedly due to a knife being present.
Gave details of the delay in reporting the incident (filed on August 5, 1982) and undergoing a medico-legal examination (on August 6, 1982) which confirmed her pregnancy, later resulting in the birth of twins.

Geneveza claimed familiarity with Nenita from previous interactions, identifying her as a vendor or customer near his workplace at Cosmos Bottling Company.
He contended that on the night in question, he met Nenita while she was in her carinderia, invited her to a walk, and subsequently treated her to merienda.
Stated that their presence at Antipuesto’s house was with a peaceful or romantic intent; their relationship was consensual and romantic rather than coercive.
Affirmed that he provided her P50.00 for transportation after the encounter and left early in the morning to report for work.

Confirmed that on March 18, 1982, he had been drinking with Geneveza and other companions near the Cosmos Bottling Company.
Related that they encountered Nenita, and that Geneveza repeatedly invited her, who at one point consented despite initial reluctance.
Noted that the atmosphere appeared akin to a romantic liaison rather than an act of force.

Post-conviction, on December 13, 1985, the trial court convicted Geneveza beyond reasonable doubt.
On April 17, 1986, the accused filed a Motion to Fix Bail Pending Appeal, which was subsequently amended and approved, with bail increased from P20,000.00 to P30,000.00.

The complainant provided inconsistent testimonies regarding her initial acquaintance with Geneveza.
Conflicting details arose concerning whether she lost consciousness during the encounter and whether the act was violent or consensual.
The unexplained delay in reporting the incident to both her family and the authorities raised doubts about the credibility of her account.

Whether the lone and allegedly inconsistent testimony of Nenita Obogne can sustain a conviction for rape.
The impact of her explained and unexplained delays (in reporting and seeking medical examination) on her overall credibility.

Whether the complainant voluntarily submitted herself to the accused, as asserted by Geneveza and supported by corroborative witness testimony.
The determination of whether there was enough evidence to conclude that the act was consensual rather than one executed by force.

The reliability and weight of the testimony of Buenaventura Santos, Jr., and how it corroborates the possibility of a consensual romantic encounter.
The relevance of the social context (drinking spree, informal gathering) in establishing the nature of the encounter.

How the four-month delay in both seeking a medical examination and reporting the incident to authorities affects the probative value of the complainant’s testimony.
Whether such delays create reasonable doubt as to the occurrence of the crime.

Whether the prosecution has met its burden to establish the elements of rape beyond reasonable doubt.
Whether the weight of the contradictory and inconsistent evidence ultimately warrants an acquittal.