Case Digest (G.R. No. L-49616)
Facts:
The People of the Philippines v. Genaro Mendiguarin, G.R. No. L-49616, August 20, 1979, Supreme Court Second Division, Aquino, J., writing for the Court. The Second Division was composed of Barredo (Chairman), Antonio, Concepcion, Jr., and Guerrero (designated); Santos and Abad Santos were abroad.The accused- appellant was Genaro Mendiguarin; the complainant and offended party was Virginia Oliveros; the prosecution was represented by the People of the Philippines (the Solicitor General later filed a manifestation recommending acquittal). Mendiguarin appealed from the decision of the Court of First Instance of Pangasinan, Lingayen Branch I, which convicted him of rape, sentenced him to reclusion perpetua and ordered payment of P12,000 indemnity (Criminal Case No. L-1055).
Chronology: Virginia, then about 21 and employed by Mendiguarin and his wife as a helper selling glassware, testified to an alleged rape on September 12, 1974 at the house of Mendiguarin’s father in Barrio Pallas, Binmaley, Pangasinan. She described being summoned upstairs, grabbed, struck, threatened, stripped of her underwear, and vaginally penetrated despite resistance; she later told Mendiguarin’s wife about the assault. She also admitted prior intimate encounters with Mendiguarin (an embrace and kiss in a hotel in December 1973) and that she subsequently had consensual sexual relations with him on several nights after the alleged rape. On September 14, 1974 she signed a statement—typed by a policeman—declaring voluntary intercourse and that she regarded Mendiguarin as a common-law husband (Exh. 1). Five days after the alleged rape her father fetched her; a municipal health officer examined her on September 18 and found lacerations of the hymen and other findings reported in the health certificate.
Procedural events: Her father reported the alleged rape to the Constabulary and she executed a statement before Sergeant Galsim recounting rape and also admitting prior voluntary intercourse (Exh. 2). She filed a complaint on October 10, 1974; the information was filed July 21, 1975. Mendiguarin was arrested October 18, 1978 and arraigned November 9, 1978, pleading not guilty. At trial the defense maintained that the relations were consensual and that Virginia had eloped with Mendiguarin and had sexual intercourse freely on successive nights; police witnesses authenticated her prior signed statements. Virginia testified at trial (November 22–29, 1978) and was shown t...(Subscriber-Only)
Issues:
- Was the accused, Genaro Mendiguarin, proved guilty of rape beyond reasonable doubt?
- May the uncorroborated testimony of the offended woman be relied upon when her sincerity and candor are open to...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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