Case Summary (G.R. No. 200080)
Facts of the Case
On February 1, 2001, Cayanan, the victim's brother-in-law residing nearby, forcibly raped AAA inside her house in Bulacan. The victim was asleep when Cayanan caressed and kissed her, threatening her with a knife to submit and not disclose the incident. Later, on February 26, 2001, Cayanan forcibly abducted AAA near her school, preventing her from shouting for help, and transported her to various locations before raping her again at his sister’s house.
Evidence and Witness Testimony
AAA testified about the rapes and the abduction, stating that initial silence was due to shock. Her classmate Adriano, who witnessed part of the abduction, and the victim’s mother corroborated her accounts. A psychiatrist from the National Center for Mental Health confirmed the presence of mental depressive symptoms and sexual abuse. The defense presented a “sweetheart defense,” asserting a consensual relationship supported by two love letters allegedly from AAA.
Trial Court's Findings and Ruling
The RTC found the sweetheart defense unconvincing, highlighting the use of force and threats as established by the prosecution’s evidence. The court ruled the love letters lacked authenticity and probative value. Consequently, the RTC convicted Cayanan of Qualified Rape and Forcible Abduction with Qualified Rape, sentencing him to reclusion perpetua without eligibility for parole. The RTC awarded damages to the victim.
Court of Appeals Decision and Modifications
The CA affirmed the RTC’s conviction but increased the award of civil indemnity and moral damages and added exemplary damages in both criminal cases. The CA agreed that the forceful nature of the offenses was proven beyond reasonable doubt and rejected the sweetheart defense due to lack of compelling or independent evidence, such as authenticated tokens or photographs.
Supreme Court’s Review and Ruling
The Supreme Court found no reversible error in the CA’s affirmation, emphasizing that rape absorbed the crime of forcible abduction when the abduction’s primary purpose is rape. Since Cayanan’s abduction of AAA led to rape, the Court ruled that the conviction for forcible abduction should be set aside and qualified rape upheld. The court cited prevailing jurisprudence requiring independent evidence to establish a consensual relationship for a sweetheart defense, which was absent in this case.
Damages and Interest
The Court upheld the CA’s increase i
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Background and Procedural History
- Accused-appellant Marvin Cayanan was convicted by the Regional Trial Court (RTC) of Malolos City, Bulacan, Branch 77, of Qualified Rape (Criminal Case No. 1499-M-2001) and Forcible Abduction with Qualified Rape (Criminal Case No. 1498-M-2001).
- The RTC imposed the penalty of reclusion perpetua without eligibility for parole for each offense.
- The Court of Appeals (CA), in the case CA-G.R. CR-HC No. 04256, affirmed the conviction with modifications, increasing the civil indemnity and moral damages awarded by the RTC.
- The CA awarded civil indemnity of P75,000.00 in each case, increased moral damages, and exemplary damages of P30,000.00 in both criminal cases.
- Marvin Cayanan sought a review of the CA Decision dated July 14, 2011, leading to the present resolution by the Supreme Court.
Facts of the Case
- The victim, a 15-year-old female designated as AAA to protect her identity, was sexually assaulted by Marvin Cayanan, her brother-in-law.
- On February 1, 2001, while AAA was asleep alone at home in Bulacan, Cayanan caressed, kissed, forcibly removed her shorts, and forcibly consummated sexual intercourse with her under threat of death with a knife.
- On February 26, 2001, Cayanan forcibly abducted AAA near her school by pulling her towards a tricycle driven by his uncle, covered her mouth when she tried to yell, and took her to various locations including a dress shop and Jollibee outlet.
- The victim was then taken to Cayanan's sister’s house, where he raped her inside a bedroom.
- After the incident, barangay officials induced AAA to execute a document claiming voluntary accompaniment, but she was returned home later by Cayanan’s mother and sister-in-law.
- AAA disclosed the crime only after her friend, Armina Adriano, informed her family.
- AAA suffered mental and depressive symptoms due to the sexual abuse, as confirmed by a resident psychiatrist from the National Center for Mental Health.
Evidence and Testimonies
- AAA’s testimony detailed the forcible nature of the assaults, threats of harm, and abduction.
- Adriano and the victim’s mother corroborated AAA’s accounts.
- Expert psychiatric testimony verified AAA’s mental condition stemming from the abuse.
- Cayanan advanced the “sweetheart defense,” alleging consent and a romantic relationship between him and AAA.
- Two love letters purportedly from