Title
People vs. Regala y Manuod
Case
G.R. No. 140995
Decision Date
Aug 30, 2001
A dental technician is convicted of raping a 16-year-old girl, with the court affirming that absence of violence or physical trauma does not negate rape, and ordering civil indemnity to the victim.
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Case Digest (G.R. No. 140995)

Facts:

  • The case involves the People of the Philippines as the plaintiff-appellee against Danilo Regala y Manuod, the accused-appellant.
  • Events occurred on February 17 and 18, 1997, in Malabon, Philippines.
  • Sarah Jane Villaluz, a 16-year-old high school student, visited Regala's dental clinic to order dental retainers.
  • On February 18, Regala approached Sarah Jane with a kitchen knife, threatening her and her family.
  • He forcibly dragged her into a room, undressed her, and sexually assaulted her.
  • After the incident, Sarah Jane confided in a helper at Regala's house and reported the assault to the barangay.
  • An Information for Rape was filed, and a medical examination revealed her hymen was intact but did not rule out sexual intercourse.
  • Regala's defense was based on denial, claiming Sarah Jane consented to the act.
  • On October 29, 1999, the trial court found Regala guilty of rape, sentencing him to reclusion perpetua and ordering him to pay P75,000.00 in moral damages.
  • Regala appealed, arguing the trial court erred in its decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the conviction of Danilo Regala y Manuod for rape.
  • The Court modified the moral damages awarded to Sarah Jane Villaluz from P75,000.00 to P50,000.00....(Unlock)

Ratio:

  • The Supreme Court held that the trial court did not err in its conviction, as the evidence, particularly Sarah Jane's testimony, was credible and consistent.
  • The Court noted that lack of physical resistance does not negate rape, especially when intimidation is involved.
  • Regala's threats created a coercive environment, making Sarah Jane's compliance understandable.
  • An...continue reading

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