Case Digest (G.R. No. 130969)
Facts:
People of the Philippines v. Roberto San Juan, G.R. No. 130969, February 29, 2000, Supreme Court Second Division, Bellosillo, J., writing for the Court.The criminal information, filed June 30, 1994, charged Roberto San Juan (accused-appellant) with rape for having carnal knowledge of Rowena Morla, a 16‑year‑old high‑school student, while pointing a bladed instrument at her neck (violence and intimidation). The Regional Trial Court of Talavera, Nueva Ecija convicted the accused on April 1, 1997, sentenced him to reclusion perpetua, ordered indemnity of P50,000.00 and costs, and prescribed crediting his detention period subject to a written undertaking.
Rowena testified that on the night of May 4, 1994 she was awakened by a kiss, saw Roberto near her with a seven‑inch blade at her right neck while he pinned her; he ordered her to keep silent and forced her out of the house, holding the knife at her nape as they walked by two houses to an open field behind a chapel about forty meters away. She said he ordered her to lie down, removed parts of her clothing, mounted and inserted his penis into her vagina twice while she stayed passive for fear the knife would wound her. She returned home about twenty minutes past midnight, woke and told her parents, and within about 45 minutes underwent medical examination (around 1:05 a.m., May 5) showing fresh laceration of the hymen and contusion/laceration of the labia minora; she then filed a sworn statement with police.
The accused maintained he and Rowena had been sweethearts since January 1, 1994; he went to her house past 10:00 p.m. upon her invitation, she invited him into her bedroom, they later went behind the chapel to avoid discovery, and there they consensually had sexual intercourse and even planned to elope. He said she offered to fetch her necklace and clothes at home but did not return; he later went home about 2:00 a.m. and was met by police and subjected to preliminary investigation. His sister Ludy corroborated seeing them together at her store and that Rowena confirmed the relationship on February 14, 1994.
The trial court credited Rowena’s testimony as credible and convicting. On appeal to the Supreme Court (the record does not set out intermediate appellate proceedings), the Court reviewed the evidence de novo, examined inconsistencies and improbabilities in Rowena’s accounts (including differences between her preliminary investigation statement and trial testimony, lack of e...(Pro-only)
Issues:
- Did the prosecution prove beyond reasonable doubt that accused‑appellant used violence or intimidation to effect the rape such that a conviction is warranted?
- Was the trial court’s credibility finding in favor of the complaining witness sustainable in light of the inconsistencies, improbabilities, and corrobora...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)