Case Summary (G.R. No. L-40880)
Charges and Proceedings
Romeo Corrales was charged with the crime of rape based on a complaint filed by the victim, Milagros Miranda, which detailed an incident occurring on December 29, 1983, wherein Corrales allegedly forced himself on her by employing intimidation and threats. Following the arraignment, Corrales entered a plea of not guilty, leading to a trial where he was ultimately convicted and sentenced to Reclusion Perpetua by the Regional Trial Court of Caloocan City.
Prosecution's Evidence
The prosecution's evidence established that on the night in question, Milagros Miranda was at home alone and was awakened by Romeo Corrales, who threatened her with a pointed instrument, demanding compliance with his sexual advances. Despite being seven months pregnant and pleading with Corrales, he proceeded to sexually assault her. The victim testified that she felt intimidated and did not resist out of fear for her life, which ultimately led her to report the incident to the authorities despite being threatened.
Accused-Appellant's Claims
In his appeal, Corrales argued two primary errors: the trial court's conclusion that he used force and intimidation in committing the crime, and the determination that he was guilty beyond a reasonable doubt. He contended that the victim did not show any resistance and highlighted the delay between the incident and the report as potentially undermining her credibility.
Assessment of Intimidation and Evidence
The court found that Milagros’s fear, stemming from Corrales's threats, sufficiently constituted force and intimidation. The victim's consistent testimony regarding her fear of death was decisive, as established legal precedents indicate that intimidation need not be physical force but can instead be psychological, rendering physical resistance irrelevant. The court referenced pertinent cases underscoring that lack of physical injuries or strong resistance does not negate the occurrence of rape if the victim's will was successfully overcome by fear.
Delay in Reporting the Incident
Corrales’s argument regarding the delay in formal reporting was dismissed, as the court recognized the victim's fear and traumatic experience impacted her actions. The short timeframe between the incident and the report undermined the assertion that the delay compromised her credibility. The court emphasized that inconsistencies in the victim's testimony were minor and did not detract from her overall credibility.
Alibi Defense and Identity
The accused provided an alibi, asserting he was at his mother-in-law's house at the time of the incident. However, the victim'
...continue readingCase Syllabus (G.R. No. L-40880)
Case Overview
- The case revolves around the accusation of rape against Romeo A. Corrales, filed by the victim, Milagros Tabaquero de Miranda.
- The incident allegedly occurred on December 29, 1983, in Caloocan City, Philippines.
- The Regional Trial Court of Caloocan City found Corrales guilty, sentencing him to Reclusion Perpetua.
- The accused-appellant, Corrales, subsequently appealed the decision.
Background of the Case
- The complaint stated that Corrales, with lewd designs and by means of force and intimidation, had sexual intercourse with Milagros Miranda against her will.
- Upon arraignment, Corrales entered a plea of not guilty.
- The trial commenced, leading to his conviction based on the prosecution's evidence.
Summary of the Prosecution's Evidence
- Milagros Miranda testified that she was alone at home when Corrales entered and threatened her with a pointed instrument, warning her not to shout.
- Corrales instructed her to remove her clothes, and although she pleaded with him, he proceeded to commit the act of rape.
- After the assault, Corrales threatened Miranda against reporting the incident, but she eventually informed her parents and reported it to the police.
Accused-Appellant's Assignments of Error
- Corrales raised two primary errors on appeal:
- The trial court err