Title
People vs. Lampaza
Case
G.R. No. 138876
Decision Date
Nov 24, 1999
The Supreme Court upholds Egmedio Lampaza's rape conviction, affirming the victim's credible testimony despite claims of a romantic relationship and delayed reporting.
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Case Digest (G.R. No. 138876)

Facts:

  • Egmedio Lampaza was charged with rape against Teodora Wacay.
  • The incident occurred on March 20, 1988, in Tobias Fornier, Antique, Philippines.
  • The charge was filed by Assistant Provincial Fiscal Juan C. Mission Jr. on May 25, 1988.
  • Lampaza allegedly used lewd design, intimidation, and violence to have carnal knowledge of Wacay without her consent.
  • During the arraignment on June 9, 1988, Lampaza pleaded not guilty.
  • The prosecution presented several witnesses, including Wacay, who testified about the attack.
  • Wacay described being approached from behind, having her arms twisted, and being taken to an uninhabited nipa hut where she was raped under threat of a bolo.
  • Wacay reported the incident to her husband and mother the same evening.
  • The Regional Trial Court (RTC) found Lampaza guilty on March 14, 1994, sentencing him to 12 years and 1 day to 20 years in prison and ordering him to pay P30,000 in damages.
  • Lampaza appealed, and the Court of Appeals (CA) affirmed the conviction, modifying the penalty to reclusion perpetua and increasing moral damages to P50,000.
  • The CA certified the case to the Supreme Court for further review.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the trial court did not err in finding that force and intimidation were used by the accused against the complainant.
  • The Court held that the sexual intercourse was not consensual, rejecting the accused's claim of a romantic relationship.
  • The Court found...(Unlock)

Ratio:

  • The Supreme Court emphasized that force and intimidation are critical elements in establishing the crime of rape.
  • The victim's testimony was deemed credible and consistent with the nature of the crime, as she described being physically overpowered and threatened with a weapon.
  • Discrepancies in the victim's statements were large...continue reading

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