Title
People vs. Loredo
Case
G.R. No. L-64167
Decision Date
Jul 31, 1984
A 14-year-old alleged rape by her uncle; court acquitted due to prior relationship, lack of resistance, and inconsistent testimony, citing insufficient evidence.

Case Digest (G.R. No. 168486)
Expanded Legal Reasoning Model

Facts:

  • Allegations as Presented by the Prosecution
    • The complainant, Maxiline Bautista, testified that on March 4, 1979 (a Sunday) around 7:00 p.m., she left her house in Sinuaga, Pototan, Iloilo to attend a bible study in a nearby barrio chapel.
    • On her way, along a small path about 4 meters from her house, she was approached by the accused, Edwin Loredo, who said: “Bing, you go to the house of Mildred, I have something to tell you.”
    • Trusting him as a relative, she consented and followed him to a house 50 meters away, which belonged to Mildred Casquete. This house, built of bamboo and dark due to the absence of its regular inmates, had a fenced lower portion used as a storeroom for firewood.
    • Once inside, Edwin embraced her. Although she was initially inclined to run away, he held her hand and repeatedly insisted that they engage in sexual intercourse.
    • The complainant stated that as she attempted to resist, the accused produced a knife, pointed it at her, and forcibly manipulated her by pulling down the zipper of his pants.
    • Amidst her accidental stumble into a hole, she ended up lying flat on the ground while the accused pinned her with his legs, removed her long pants and panties, and then removed his own pants.
    • Claiming that she was warned of further physical harm (specifically, being “boxed on the mouth” if she moved), she remained in place despite the conditions and the presence of a fence at the entrance, which hindered her escape.
    • For almost one hour under the house, the accused allegedly carried out the sexual act by inserting his penis into her vagina—a process described as prolonged due to the size of his member—during which she reportedly experienced pain and minimal physical resistance.
    • After completing the act, the accused ordered her to get up, put on her underwear, and return home after advising her not to speak of the incident.
    • Notably, the complainant did not report the incident immediately to the authorities and only sought medical attention much later when she was hospitalized for uterine bleeding.
  • The Accused’s Version and Alternate Narrative
    • Edwin Loredo admitted engaging in sexual intercourse with the complainant but denied that the encounter constituted rape.
    • He contended that the sexual interaction was consensual, as the parties had been sweethearts since December 1978—a relationship allegedly initiated after advice from the complainant’s sister, Marlene Bautista.
    • The accused maintained that the initial reluctance to court Maxiline was resolved when she accepted his proposal, and the couple subsequently engaged in several consensual encounters.
    • Specific details include a consensual meeting on February 14, 1979, where they attempted intimacy but did not consummate, followed later by the encounter on March 4, 1979, which was characterized, according to his narrative, as a mutual agreement for intimacy rather than a forceful act.
    • Subsequent interactions, such as another encounter on March 12, 1979, further support the defense’s assertion of an ongoing consensual relationship.
    • Plans for marriage were also advanced when, on May 12, 1979, representatives from both families met to arrange the wedding and discuss future plans, reinforcing the alleged consensual nature of their relationship.
  • Contextual and Circumstantial Factors
    • Despite the mutually agreed relationship, complications arose when the complainant became pregnant, which led her father, Maximo Bautista, to confront the situation.
    • The filing of the rape complaint on June 13, 1979, has been interpreted by the Solicitor General as a vengeful act by the complainant’s family, possibly fueled by the complications arising from the pregnancy and a subsequent abortion.
    • Witnesses and circumstantial evidence noted that there was no loud cry for help from the complainant, even though the scene was close to other houses and a church, and that she did not report the incident to the authorities immediately.
    • Testimonies during the trial revealed that the complainant’s actions (or lack thereof) and physical responses—such as minimal resistance, silence during the act, and later explanations given on cross-examination—cast doubt on the occurrence of a forceful rape.
    • The physical setting (a dimly lit, fenced, and secluded storeroom) and the behavior of both parties have proven pivotal in examining whether the encounter was inherently coercive or consensual.

Issues:

  • Sufficiency and Credibility of the Complainant’s Testimony
    • Whether the complainant’s account—being uncorroborated, contradictory, and containing internal inconsistencies—is sufficient to prove rape beyond reasonable doubt.
    • Whether the physical and behavioral evidence, such as the absence of a cry for help and the opportunity to escape, undermines the claim of non-consent.
  • Nature of the Sexual Encounter
    • Whether the circumstances of the encounter (location, the complainant’s actions, and the accused’s conduct) indicate a consensual sexual relationship rather than a forcible act.
    • How the alleged absence of overt resistance or immediate reporting impacted the determination of consent versus coercion.
  • Effect of Circumstantial Evidence
    • The impact of the complainant’s subsequent conduct (post-incident silence, delay in reporting, and eventual medical examination) on the overall credibility of the rape allegation.
    • Whether the family dispute and vengeful motives attributed by the Solicitor General provide a sufficient basis to doubt the prosecution’s case.
  • Role of Corroborative Evidence
    • The extent to which corroborative evidence—or the lack thereof—plays a role in validating or refuting the complainant’s version of events.
    • The comparison of the victim’s account with the defense’s narrative and the testimonies of other witnesses.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.