G.R. No. 193178 - Philippine Savings Bank vs. Spouses Castillo

The incident occurred on the evening of March 11, 2011, in Brgy. Tampac, Aguilar, Pangasinan.
The accused, Jimmy Ulanday “Saroy,” was charged with rape under Article 266-A, paragraph 1(a) of the Revised Penal Code.
The Information alleged that with “lewd designs” and armed with a knife, the accused forcibly dragged [XYZ] to a secluded area at a neighbor’s house, removed her short pants and underwear, and raped her against her will.

[XYZ], aged twenty-four, was watching a dance party from a window when the accused, recognized from previous encounters at a tong-its game, entered her house.
The accused overpowered her by using force, covering her mouth, and pointing a knife to threaten her.
He dragged her to a dark, uninhabited area at the back of a neighbor’s house, where he removed her garments and committed the rape.
Despite her struggle, the victim could not resist due to the force and intimidation exerted by the accused.

Direct testimony from [XYZ] detailed the events, including the accused’s entry, his armed threat, and the manner in which he overpowered her.
BBB, the victim’s half-sister, testified that during a family gathering, the accused admitted to having sexual intercourse with [XYZ] and was subsequently assaulted by male relatives.
Dr. Maria Gwendolyn Luna, who conducted a medico-legal examination on May 16, 2011, noted the presence of old, healed deep lacerations in the victim’s hymenal area at the 4, 6, and 7 o’clock positions.
A police blotter and stipulated records confirmed the occurrence of the incident.

After the issuance of a warrant and arrest of the accused on August 17, 2011, he pleaded not guilty upon arraignment.
During the pre-trial conference, both parties stipulated to critical documents such as the medico-legal certificate and the police blotter entry.
The trial court (RTC, Branch 69 in Lingayen, Pangasinan) found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua, along with monetary awards to [XYZ] as civil indemnity and moral damages.
The decision was modified on appeal by the Court of Appeals, which declared the accused ineligible for parole, ordered exemplary damages, and added interest on the monetary awards.
The accused raised his sole point of error on appeal regarding the sufficiency of the evidence proving his guilt beyond reasonable doubt, ultimately prompting the review by the Supreme Court.

The defense presented an alternative narrative that the accused merely had a brief conversation with the victim, who was seen from her window during a wedding dance party, and denied any admission of rape at a subsequent family gathering.
It contended that discrepancies such as the precise door through which the accused entered or minor lapses in the victim’s account should mitigate the credibility of her testimony.
The defense also questioned the timing of Dr. Luna’s medical findings, arguing that the “old” lacerations indicated sexual contact on a different occasion from the alleged assault.

The testimony of [XYZ] remained consistent, particularly regarding how the use of a knife, the removal of clothes, and physical force were employed by the accused.
Medical evidence of healed hymenal lacerations provided crucial corroborative support for the victim’s account.
The courts noted that a rape victim’s delayed reporting and emotional state, resulting in minor inconsistencies, were understandable consequences of the traumatic experience.
The defense’s emphasis on these slight discrepancies was rejected as insufficient to create reasonable doubt regarding the accused’s guilt.

Whether the evidence presented by the prosecution was sufficient to establish, beyond reasonable doubt, that the accused committed the crime of rape.

The main contention centered on whether the elements of the crime—carnal knowledge obtained through force, threat, or intimidation—were clearly demonstrated.

The credibility of the victim’s testimony in the face of alleged inconsistencies.

Whether minor lapses in her recollection or details such as the specific location of entry could undermine her overall account.

The significance of the medical evidence in corroborating the victim’s account.

Whether Dr. Luna’s findings of healed hymenal lacerations sufficiently supported the occurrence and timing of the alleged rape.

The propriety of the penalties imposed, including the sentence of reclusion perpetua and the awarded damages.

Whether additional qualifiers, such as parole ineligibility, and the modifications on the monetary awards by the Court of Appeals fit within the established legal framework.