Facts:

The case involves the accused-appellant, Jupiter Villanueva y Bautista, also known as "Peter," who was charged with forcible abduction with rape. The events took place on July 27, 2006, in Antipolo City, Philippines. The victim, a fifteen-year-old minor referred to as AAA, was abducted while walking to buy a gift for her mother. Two men, whose faces were covered, approached her and threatened her with a knife, forcing her to walk with them. During the abduction, AAA noticed one of the men, later identified as the accused-appellant, who was part of the group. She was subsequently forced into a tricycle, where she was taken to an undisclosed location. There, she was subjected to physical violence, forced to drink a bitter liquid, and raped. The following morning, AAA was found in a tricycle near her home, disoriented and in pain, with evidence of sexual assault. She reported the incident to her mother and later underwent a medico-legal examination, which confirmed the...

Facts:

Antecedent Facts

• On July 27, 2006, AAA, a 15-year-old minor, was abducted by four men in Antipolo City. The men, armed with a bladed weapon, forced her into a tricycle, blindfolded her, and took her to an unknown location.
• During the abduction, AAA was subjected to physical abuse, including being slapped, forced to drink a bitter liquid, and kissed on the neck. She lost consciousness and later woke up in a tricycle the next morning, feeling pain and noticing her bra had been removed and her panties had blood stains.
• AAA reported the incident to the police and underwent a medico-legal examination, which confirmed she had been raped. She identified accused-appellant, Jupiter Villanueva, as one of her abductors during a police line-up.

Prosecution’s Case

• The prosecution presented AAA, her aunt BBB, PC/Insp. Marianne Ebdane (medico-legal officer), and SPO1 Ma. Theresa Bautista (Women’s Child Protection Desk officer) as witnesses.
• AAA testified in detail about the abduction, the physical abuse, and her subsequent identification of accused-appellant.
• The medico-legal report confirmed AAA’s hymen had fresh lacerations and contusions, consistent with rape.

Defense’s Case

• Accused-appellant denied the allegations, claiming he was with his girlfriend in Parang, Marikina, at the time of the incident. He argued that the police influenced AAA’s identification of him.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Elements of Forcible Abduction and Rape:

   • Forcible abduction requires (1) a woman taken against her will, and (2) lewd designs. Rape requires carnal knowledge through force, intimidation, or when the victim is unconscious.
   • The prosecution proved all elements: AAA was abducted, raped, and identified accused-appellant as one of her abductors. The medico-legal report corroborated the rape.

2. Credibility of AAA’s Testimony:

   • AAA’s testimony was consistent, credible, and corroborated by medical evidence. The Court upheld the trial court’s findings, emphasizing that the victim’s testimony in rape cases is given great weight.

3. Weakness of Alibi and Denial:

   • Accused-appellant’s alibi was weak as he failed to prove it was physically impossible for him to be at the crime scene. Denial and alibi are inherently weak defenses, especially against positive identification by the victim.

4. Absorption of Forcible Abduction by Rape:

   • The Court ruled that forcible abduction is absorbed by rape when the primary intent of the abductor is to commit rape. Thus, accused-appellant was convicted solely of rape.

5. Damages and Penalty:

   • The Court increased the awards for civil indemnity and moral damages to P75,000.00 each, in line with prevailing jurisprudence. Exemplary damages of P75,000.00 were also awarded to deter similar acts.