Case Digest (G.R. No. L-36606)
Facts:
The case revolves around a charge of rape against Isaac Senon, Jr., who was tried in the Court of First Instance of Iloilo. The rape incident allegedly occurred on March 23, 1971, in Pototan, Iloilo, where the complainant, Thelma A. Diva, was staying as a house guest at the home of Lolita Zerrudo during a local fiesta. At about 3 a.m., when Thelma was home alone, Isaac Senon knocked on the door and forcibly entered the house. He brandished a butcher’s knife and threatened Thelma. Although she shouted for help, Senon proceeded to have carnal knowledge of her three times while threatening her life if she resisted. She sustained various injuries on her hands while attempting to defend herself. After the assault, Isaac dragged her away from the house and brought her to his residence. It was at this point where she disclosed the incident to Senon's parents.
In the early hours of March 23, Thelma's maid, concerned about her absence, informed her uncle, Elias Alarcon, who subs
Case Digest (G.R. No. L-36606)
Facts:
- The accused, Isaac Senon, Jr., was charged with the crime of rape committed on or about March 23, 1971, in Pototan, Iloilo.
- The complaint stated that the accused, armed with a sharp pointed instrument (a pinote), used force, violence, and intimidation to have carnal knowledge of the complainant, Thelma A. Diva, against her will.
- The trial record indicates that during the early hours (around 3:00 AM), the accused forcibly entered Lolita Zerrudo’s house where the complainant was staying as a house guest.
Incident and Allegations
- Entry and Attack
- The accused allegedly knocked at Lolita Zerrudo’s door and forced it open.
- Complainant, who stayed at the house due to feeling unwell from menstruation, was alone at the time.
- Once inside, the accused extinguished the light, pointed his butcher’s knife at the complainant, and coerced her through threats.
- Physical Assault and Coercion
- The accused removed the complainant’s panty and raped her on three separate occasions, warning her against resisting by holding the knife.
- When the complainant attempted to wrest the knife away, she sustained multiple injuries on her hand as corroborated by a detailed medical certificate.
- Witness Felipe Pasaporte, present in the vicinity, testified to hearing the complainant’s cry for help.
- Subsequent Developments
- After the assault, the accused forced the complainant to redress and then dragged her out of the house.
- The complainant was eventually found at the accused’s residence in Carasan, Dingle, where she informed his parents of the incident.
- The investigators, including officers Pat. Silverio Pueyo and his colleagues, later gathered evidence at both the scene and the accused’s residence, including bloodstains and corroborative testimonies.
- A medical examination by Dr. Melchor Albano provided detailed findings of multiple incised wounds, abrasions, lacerations, and an incomplete hymen, all of which supported the claim of physical violence.
Prosecution’s Narrative and Evidentiary Findings
- The accused asserted that no rape occurred as the complainant willingly participated in sexual intercourse.
- He provided a narrative in which he first met Thelma A. Diva during the fiesta in Barrio Cawayan through Lolita Zerrudo’s introduction.
- According to his account:
- He invited Thelma to a dance on the following evening after several interactions at Lolita Zerrudo’s house and another visit to Itoc Zerrudo’s nearby residence for a drink.
- On the night of March 22, 1971, after having supper with the group, he convinced Thelma to change her attire and join him to the ball, during which a consensual sexual contact allegedly ensued.
- Post-intercourse, Thelma became upset and the couple eloped.
- While crossing a bamboo foot bridge, Thelma slipped and sustained injuries (scratches and bruises), which the defendant attributed to an accident not related to his alleged violent conduct.
- Later, after meeting with both families to arrange a wedding, an unexpected complaint for rape was lodged against him on the morning of March 23, 1971.
Defendant’s Version and Alternative Narrative
- The lower court trial, conducted in Iloilo, found the evidence presented by the prosecution to be convincing.
- The accused was sentenced to reclusion perpetua, with accessory penalties including indemnification of the complainant and payment of costs.
- Following the conviction, the accused appealed the decision, leading to the present review by the appellate court.
Procedural History and Ultimate Outcome
Issue:
- The credibility and consistency of the complainant’s testimony.
- The physical evidence of multiple injuries consistent with a violent assault.
- Whether the discrepancies or minor details in the complainant’s narrative, including alleged inconsistencies, undermine the substance of her testimony.
- Whether the defendant’s version, asserting a consensual sexual relationship and an accidental nature of some injuries, can effectively rebut the testimony and evidence of non-consent and violence.
Whether the evidence on record is sufficient to prove beyond reasonable doubt that Isaac Senon, Jr. committed the rape of Thelma A. Diva.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)