G.R. No. 240873 - Calida vs. Trillanes IV

On May 28, 1972, Adelaida Vicario, accompanied by her betrothed Macario Castillo, her mother, and her younger sister Greta, went to the poblacion of Capul for the purpose of having her wedding dress sewn by Marcelina Magloyoan.
At about 7:00 p.m., after having her measurements taken by the seamstress, the group was returning home when, approximately 20 meters from the seamstress’s house, they encountered Arcito Magdaraog coming from darkness.
According to the prosecution’s account, the accused forcibly grabbed Adelaida’s left hand and, while pointing his revolver at Diena Castillo (the sister of Macario Castillo), declared, “This is mine, this is not yours,” thereby seizing the complainant.
Despite initial resistance by Adelaida, who struggled, kicked, and attempted to escape, the accused dragged her along: first toward a seashore and then into more secluded grounds, using threats and gunfire when Diena attempted to intervene.

The accused, after forcing Adelaida to a sitting position near a fence at the seashore, escalated his use of force by firing his revolver to deter any rescue attempts by the companions.
He dragged her to the house of Mrs. Maria Manaog where, after a series of hostile actions including knocker violence and the physical confinement of the complainant inside a room, he overpowered her resistance.
The testimony detailed that the accused removed the complainant’s pants and bikini by force, inserted his fingers, and eventually consummated the act of sexual intercourse despite her persistent protests and physical struggles.
In the morning, after hearing her father calling for her, Adelaida managed to escape from the confined room and informed her father about the incident, even as the accused threatened the family from the gate of Mrs. Manaog’s house.

Adelaida sought medical attention on May 29, 1972 at a hospital in Allen, where Dr. Conchita O. Tomada documented findings including fresh lacerations on the vagina and ruptured hymenal tears at specified clock positions, as well as abrasions and hematomas on her feet.
Following the examination, the complainant immediately proceeded to file a complaint at the Office of the Fiscal. Her prompt filing (on May 30 and 31) and the subsequent execution of affidavits by both her and witness Diena Castillo cemented the prosecution’s case.
The medical certificate (Exhibit ‘A’) and the complainant’s consistent testimonies provided critical evidence of the forcible nature of the act, highlighting both physical injuries and the psychological trauma suffered.

The defendant-appellant acknowledged that a sexual encounter with the complainant took place but contended that it was consensual, asserting that they were sweethearts and had even arranged to elope.
To support his claim, he produced a letter from the complainant written months before the incident, suggesting affection and an agreement to elope, although his account differed significantly on the use of force.
When circumstances shifted during the evening—reportedly due to the complainant’s changes and the intervention of her companions—the accused alleged that he merely attempted an act under an agreed plan rather than an act of abduction or rape.
Observations of his subsequent conduct, including his immediate flight to different towns (with inexplicably high travel expenses) and his use of an official service pistol in the commission of the crime, were interpreted as indicative of his awareness of guilt and an attempt to evade accountability.
Additional evidence included an alleged offer by the accused’s cousin, Lorenzo Guardiano, to pay the complainant money to drop the charges; this attempt at compromise, though against the law in criminal cases, further undermined the defendant’s claim of consensual intercourse.

Whether the evidence presented sufficiently proves that the complainant was forcibly abducted and raped, notwithstanding the defendant’s claim of consent.
Whether the inconsistencies in the defendant-appellant’s account and his subsequent flight from the scene indicate consciousness of guilt.
Whether the absence of certain physical evidence (such as the torn garment) and seemingly contradictory details in the defendant’s narrative are adequately addressed by the prosecution’s evidence and witness testimonies.
Whether the swift legal actions taken by the complainant—including the immediate medical examination and filing of complaints—corroborate her account of the crime.
Whether the abuse of the defendant’s status as a policeman and the unauthorized use of his service firearm in the commission of the crime warrant a graver penalty.