Case Summary (G.R. No. 122498)
Allegations and Events of the Crime
The Information presented alleged that Cajara, who is related to Cajote as her brother-in-law, employed force and intimidation to gain carnal knowledge of her against her will. On the night of the incident, Marita, then 16 years old, was sleeping with Cajara, his common-law wife Merly Tagana, and their children in a single-room house. Around 2 a.m., Marita was awakened by Cajara, who restrained her and threatened her life with a bolo. Despite her vocal protests, Cajara proceeded to assault her, ultimately completing the act of sexual violence while Merly and the children were present but did not intervene effectively.
Aftermath and Reporting the Crime
After the assault, Marita fled to seek help. She initially confided in her sisters, who advised against filing a complaint due to fears of retribution from Cajara, known in the community for past violent acts. A barangay official, despite being aware of the situation, echoed the caution against reporting. Ultimately, Marita reported the incident to the police, leading to a medical examination that confirmed signs consistent with sexual assault.
Defense and Trial Proceedings
During the trial, Cajara denied the allegations, asserted an alibi, and claimed that Marita's half-sister, Merly, supported his case. Merly claimed that if Marita was indeed assaulted, it would not be her husband's fault. The trial court found Cajara guilty based on credible testimony from Marita, despite the defense's arguments suggesting bias and the credibility of the common-law wife's testimony.
Legal Findings and Conviction
The trial court convicted Cajara of rape under Article 335 of the Revised Penal Code, invoking aggravating circumstances including the victim's age, familial relationship, and the act being committed in the presence of relatives.
Appeal and Modification of Conviction
On appeal, significant arguments arose regarding whether the elements necessary for Qualified Rape were adequately pleaded in the Information. The court noted that while the relationship by affinity was alleged, the lack of legal marriage between Cajara and Merly negated that qualification. Furthermore, the specific circumstance of the crime being committed in view of relatives was not included in the charges, leading to an erroneous conviction for Qualified Rape rather than Simple Rape.
Application of Law and Conclusion
The 1987 Philippine Constitution guarantees the right
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Case Overview
- The case involves Elmedio Cajara, who was found guilty of Qualified Rape and sentenced to death by the trial court.
- The incident occurred on May 30, 1994, in Barangay Serum, Basey, Samar, where Cajara, related by marriage to the victim, Marita B. Cajote, allegedly raped her using force and intimidation.
- The trial court's decision was reviewed automatically due to the imposition of the death penalty.
Factual Background
- Marita Cajote, a 16-year-old resident of Manila, arrived in Basey, Samar, on May 18, 1994, to visit her sister Marie.
- She was fetched by her sister Meling and her husband, Elmedio Cajara, who took her to their home, which consisted of a single room.
- On the night of May 30, 1994, Marita was awakened around 2:00 AM by Cajara, who threatened her with a bolo (machete) and raped her while Meling and their children were present in the room.
Details of the Incident
- Cajara held Marita down, removed her pants and panty, and began to sexually assault her despite her cries for help.
- Meling attempted to intervene but was physically assaulted by Cajara and was unable to stop the attack.
- After the assault, Marita managed to escape and sought refuge with her sisters, where she revealed the incident but was initially discouraged from filing charges due to fear of retaliation from Cajara.
Medical Examination
- Marita was examined by