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
Case Digest (G.R. No. 138876)
Facts:
The case involves Egmedio Lampaza, the accused-appellant, who was charged with the crime of rape against Teodora Wacay, the offended party. The incident occurred on March 20, 1988, in Tobias Fornier, Antique, Philippines. The charge was formally filed by Assistant Provincial Fiscal Juan C. Mission Jr. on May 25, 1988, stating that Lampaza, with lewd design and through intimidation and violence, had carnal knowledge of Wacay without her consent. During the arraignment on June 9, 1988, Lampaza pleaded not guilty.
The trial commenced, and the prosecution presented several witnesses, including Wacay herself, who testified that she was attacked by Lampaza while she was at her farm. She described how he approached her from behind, twisted her arms, and forcibly brought her to an uninhabited nipa hut where he raped her while threatening her with a bolo. Wacay reported the incident to her husband and mother the same evening.
The Regional Trial Court (RTC) of San Jose, Antique, found Lampaza guilty of rape on March 14, 1994, sentencing him to an indeterminate prison term of 12 years and 1 day to 20 years, along with an order to pay Wacay P30,000 in damages. Lampaza appealed the decision, and the Court of Appeals (CA) affirmed the conviction but modified the penalty to reclusion perpetua and increased the moral damages to P50,000. The CA certified the case to the Suprem...