G.R. No. L-38449 - People vs. Manzano

The case involves the conviction of Dominador Manzano, alias “Doming”, for the crime of rape by the Court of First Instance of Pangasinan, Third Judicial District, Branch X.
The decision of the trial court was appealed and subsequently certified to the Supreme Court for review, given the error in imposing an indeterminate sentence for a crime whose penalty is reclusion perpetua.
The Court of Appeals’ certification emphasized the necessity of Supreme Court review in cases imposing life imprisonment terms.

On November 28, 1968, in the municipality of Mabini, Pangasinan, the offended party, Jovita Nacional (17 years old), was sent to buy string beans.
After a fifteen-minute journey to Crespo Balmania’s house, where she initially encountered the accused along with Crespo, his wife, and children, Jovita returned home.
Approximately after crossing a bridge, Dominador Manzano caught up with her, forcibly subdued her by covering her mouth and restraining her, and carried her to an uninhabited, stony area on a hill.

During the struggle, despite Jovita’s resistance—manifested in boxing and futile attempts to free herself—the accused forcibly raised her dress, pulled down her garment, and proceeded to commit the act by inserting his penis into her vagina.
Jovita experienced pain and sustained physical injuries such as laceration of the hymen, later confirmed by a medical examination that documented complete lacerations at specific clock positions.
After the act, the accused threatened her with death should her parents discover the incident, compelling her to return home in distress, visibly crying and with disheveled appearance.

Jovita Nacional’s consistent testimony, supplemented by corroboration from her mother and the physical evidence (e.g., ripped and bloodied undergarment, noticeable physical injuries), supported the occurrence of rape.
Medical findings, despite some absence of external bruising, substantiated the claim through the documented hymenal lacerations indicating forcible penetration.
Witness accounts from community members, including police and local officials, affirmed that the incident took place in a secluded, uninhabited area purposely chosen to avoid detection.

The defense argued that the sexual encounter was consensual, based on an alleged prior intimate relationship between Dominador and Jovita, claiming they had been sweethearts since childhood before the accused married Erlinda Bimbo.
It was contended that any claim of rape stemmed from the offended party’s parents’ desire for retaliation following the accused’s marriage to another woman.
The defense further emphasized the absence of severe physical injuries as indicative of lack of violence during consensual intercourse.

Evidence was presented that suggested an attempt by the accused’s family (notably his mother) to settle the matter amicably with the victim’s parents.
The offer of compromise was also examined under the Rules of Court as an implied admission of guilt.
The trial court, however, rejected the defense’s version of events and found the evidence unequivocally pointing to the commission of rape.

Whether the facts establish that rape, as defined under Article 335 of the Revised Penal Code, was indeed committed by the accused.
Whether the trial court erred in imposing an indeterminate sentence instead of the mandatory reclusion perpetua prescribed for the crime.
Whether the evidence sufficiently refutes the defense’s claim of consensual sexual intercourse between the accused and the offended party.
Whether the characterization of the incident as motivated by retaliation is tenable given the testimonies and physical evidence.
Whether the aggravating circumstances—specifically, the uninhabited place and purported nocturnity—were properly assessed and should justify the award of exemplary damages alongside moral damages.