Facts:

On May 9, 1990, at approximately 6:00 AM, Maria Primavera, who was seven months pregnant, went to Sitio Racracan, Barangay Burabod, Lagonoy, Camarines Sur, at the request of her husband, Egar Primavera, to inspect their upland ricefield. Accompanied by her mother and brother, Maria separated from them to check on their camote plantation. While returning home, she encountered her first cousin, Jimmy PeAero y Barranda, who was brandishing an unsheathed bolo and had his pants unzipped. He made a lascivious remark, which frightened Maria, prompting her to cry. PeAero then ordered her to sit down, embraced her despite her attempts to resist, and ultimately forced her to the ground. He proceeded to have sexual intercourse with her while holding the bolo, which instilled fear in Maria, making her struggle futile. After the assault, PeAero threatened Maria not to tell anyone about the incident or he would kill her. On June 27, 1990, an Information for rape was filed against PeAero, a...

Facts:

1. Incident Details:

   • On May 9, 1990, at 6:00 AM, Maria Primavera, a seven-month pregnant woman, went to Sitio Racracan, Bgy. Burabod, Lagonoy, Camarines Sur, to inspect her upland ricefield. She was accompanied by her mother and brother, but they parted ways upon reaching the sitio.
   • After inspecting her ricefield, Maria proceeded to her camote plantation to gather camote and vegetables.

2. Encounter with Accused:

   • On her way home, Maria met accused-appellant Jimmy PeAero y Barranda, her first cousin. He was brandishing an unsheathed bolo, his pants were unzipped, and he made a lascivious remark: "Ika an toyo ko" (It is you whom I am looking for).
   • Maria became frightened and started crying. Accused-appellant ordered her to sit down, embraced her, and despite her resistance, overpowered her. He pushed her to the ground, tore her panty, and forcibly had sexual intercourse with her while holding the bolo in his right hand.

3. Aftermath:

   • After the act, accused-appellant threatened Maria not to report the incident or he would kill her.
   • Maria reported the incident to her husband and subsequently to the police. She underwent a medico-legal examination, which revealed physical injuries consistent with forced sexual intercourse.

4. Trial Proceedings:

   • Accused-appellant pleaded not guilty during arraignment. He admitted to having sexual intercourse with Maria but claimed it was consensual, alleging they were lovers. He argued that Maria fabricated the rape charge to avoid embarrassment and her husband's wrath.
   • The trial court rejected his defense, convicted him of rape, and sentenced him to reclusion perpetua, ordering him to pay P40,000.00 in damages.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Fear and Intimidation:

   • The Court held that Maria's fear was justified given the circumstances: accused-appellant was brandishing a bolo, his pants were unzipped, and he made a lascivious remark. These actions were sufficient to incite fear in any woman, regardless of her relationship with the aggressor.

2. Absence of Resistance:

   • The Court rejected accused-appellant's argument that Maria's failure to shout for help negated the existence of rape. It emphasized that the presence of a weapon and Maria's fragile condition (being seven months pregnant) were enough to cow her into submission. The law does not require physical resistance when intimidation is present.

3. Medical Evidence:

   • The medico-legal findings, including an abrasion at the vaginal entrance and contusions on Maria's elbow, corroborated the use of force. The torn dress and panty further supported the prosecution's claim that the sexual intercourse was non-consensual.

4. Credibility of Witnesses:

   • The Court upheld the trial court's findings on the credibility of Maria's testimony. It noted that Maria immediately reported the incident to her husband and the police, which was inconsistent with the behavior of someone fabricating a story.
   • Accused-appellant's claim that they were lovers was deemed implausible, as their alleged affair was not corroborated by credible evidence.

5. Finality of Trial Court Findings:

   • The Court reiterated that factual findings of trial courts are accorded high respect unless there is a clear showing of error. In this case, there was no compelling reason to overturn the trial court's decision.