Case Digest (G.R. No. 115656)
Facts:
The case involves the accused-appellant, Nilo Ramos y Barredo, who was charged with two counts of rape against his niece, Maria Sierra Aguilar. The incidents occurred in September 1993, where the first rape occurred in a room near the pigpen, and the second rape occurred in the comfort room. The complainant did not immediately report the incidents to her mother due to fear that she would not be believed, as the accused-appellant was her own uncle. It was only a year later, after the accused-appellant was arrested for the suspicion of killing the complainant's father, that she felt safe to report the rapes.
Issue:
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Ruling:
The threats and intimidation directed against the complainant should be viewed in the light of her perception and judgment at the time of the rape. Even though the accused-appellant was unarmed, the threats and intimidation must be considered in the context of the complainant's fear for her life and personal safety. The accused-appellant being her own uncle also exercised moral ascendancy over her.
The absence of physical resistance and the intact hymen of the complainant do not affect the prosecution of the rape. The court explained that physical resistance is not necessary to prove rape, as fear and intimidation can prevent a victim from resisting. The intact hymen does not negate the occurrence of rape, as it is possible for a woman to have had previous sexual intercourse without rupturing the hymen.
The delay in reporting the crime does not affect the credibility of the complainant. The court recognized that victims of sexual assault often delay reporting due to fear, shame, or other emotional factors. The court emphasized that the delay does not necessarily mean that the complainant's testimony is false or unreliable.
The inconsistencies in the complainant's testimony regarding the time she reported the rape to the police do not affect her credibility. The court acknowledged that minor inconsistencies are expected in testimonies, especially when recalling traumatic events. The court considered the overall consistency and coherence of the complainant's testimony, which remained credible and reliable.
The court found no ill-motive on the part of the complainant to falsely testify against the accus...(Unlock)
Case Digest (G.R. No. 115656)
Facts:
The case of People v. Ramos y Barredo involves the accused-appellant Nilo Ramos y Barredo who was charged with rape based on the complaint of Maria Sierra Aguilar. The incident happened in September 1993 at Sterling Compound, Caloocan City. The accused-appellant is the uncle of the complainant, as he is the full blood brother of her mother. The complainant alleged that she was sexually molested by the accused-appellant on two separate occasions. The first incident occurred in the evening when the complainant was looking for her younger sister and met the accused-appellant. Instead of helping her, he pulled her inside a room near the pigpen, undressed her, and raped her. The complainant did not shout for help because the accused-appellant threatened to kill her and her family. The second incident happened a week later in the comfort room, where the accused-appellant again molested the complainant. The complainant did not immediately report the incidents to her mother due to fear that she would not be believed since the accused-appellant was her own uncle.
Issue:
The main issues raised in the case are as follows:
- Whether the conviction for two counts of rape is proper based on the testimony of the complainant.
- Whether the information charged only one count of rape.
Ruling:
The Suprem...