G.R. No. 102705 - People vs. Mejorada y Sillan

On October 7, 1988, in Sta. Cruz, Davao del Sur, the accused, Doroteo Mejorada, allegedly entered the residence of Mrs. Elizabeth B. Regino using a kitchen knife as a weapon.
Despite the presence of the accused’s daughter in the house, he is alleged to have forcibly dragged Mrs. Regino from her half-finished home into a grassy area where the rape was committed.
The victim, a public school teacher and married woman, was asleep with her daughter when the intruder entered; she initially mistook him for her husband due to a brief moment of confusion under dim lighting.

On October 11, 1988, Mrs. Regino filed a complaint at the Municipal Trial Court (MTC) of Sta. Cruz, Davao del Sur.
Following a preliminary examination that found a prima facie case, the MTC transmitted the case records to the Office of the Provincial Fiscal of Davao del Sur.
An Information charging the accused with rape was subsequently filed on November 8, 1988, detailing the forcible, non-consensual act and the use of a deadly weapon.

The accused pleaded not guilty at arraignment on December 12, 1988, leading to a full trial on the merits.
Prosecution witnesses included Mrs. Regino, other persons such as Lydia Duterte, Carlito Duterte, Vice Mayor Proceso Guido, and medical testimony by Dr. Lydia Ozoa, who corroborated physical injuries and the presence of sperm cells on the victim.
The victim’s account detailed the assailant’s actions—forcefully entering, using intimidation by pressing a knife against her face, and coercing her into submission—while also noting her delayed response under threat.
Defense witnesses, including the accused’s wife Nilda and daughter Nancy, testified to support an alibi that placed the accused at a neighbor’s residence (Carding Ayop’s house in Astorga) around the time of the incident.
Physical evidence, particularly the kitchen knife identified by a witness as having been borrowed by the accused, reinforced the prosecution’s narrative of the crime.

On June 20, 1991, Branch 19 of the Regional Trial Court (RTC) of Davao del Sur rendered a decision finding Doroteo Mejorada guilty of rape beyond reasonable doubt.
The sentencing imposed reclusion perpetua (imprisonment for life) with accessory penalties, noting the aggravating circumstances related to the use of a deadly weapon and the humiliation of the victim.
The trial court opted not to award civil damages for filing fees, due to the absence of evidence indicating that such fees were paid.

The accused filed a Notice of Appeal, contending that the trial court erred in convicting him based on alleged inconsistencies and improbabilities in the victim’s testimony.
He argued that the victim’s account was “incredible,” “unnatural,” and tainted by what he described as “deliberate and studied perjury.”
The accused further advanced alternative theories, alleging that the victim was involved in an extramarital affair and that another man was responsible for the rape—a claim unsupported by substantive evidence.
The Appellee (People of the Philippines) refuted the defense’s imputation, emphasizing the consistency and cogency of the victim’s testimony supported by physical evidence and corroborative witness testimonies.

Whether the trial court erred in finding the accused guilty of the crime of rape, particularly in light of the inconsistencies alleged in the victim’s testimony.

The central question involved the credibility and reliability of the testimonies presented by Mrs. Regino and other witnesses versus the defense’s alibi.

Whether the apprehended delay in reporting the rape affected the evidentiary value and credibility of the victim’s account.

The issue here concerned whether the victim’s delayed disclosure was justified under the circumstances of coercion and fear of retribution.

Whether the non-payment of filing fees should have prevented the award of civil (moral and exemplary) damages to the offended party.

The defense contended that without evidence of fee payment, damages should not have been awarded.