G.R. No. L-37798 - People vs. Dadaeg

The defense of an accused in a serious crime such as rape requires exceptional legal skill and persuasive argumentation.
The appellant, Ramon Dadaeg, was found guilty of rape and sentenced to reclusion perpetua, along with an indemnification of P12,000.00 to the victim.
The defense submitted a brief containing five assignments of error, which lacked depth and persuasiveness, making it challenging for the court to ascertain guilt beyond a reasonable doubt.
The court emphasized the constitutional presumption of innocence, which necessitates a thorough examination of the evidence.

Teofila Dangan, the complainant, testified that on April 14, 1966, Dadaeg dismissed his class and asked her to assist in correcting test papers at his father's house.
During this time, Dadaeg allegedly dragged her into the bushes, threatened her with a knife, and raped her despite her struggles.
An eyewitness, Benjamin Bagona, observed the incident from a nearby tree, corroborating Dangan's account.
Following the assault, Dangan initially remained silent due to threats but eventually disclosed the incident to her parents.

Dangan was examined by Dr. Natividad Martin at Puerto Princesa Hospital, where the medical findings indicated:
- No visible external injuries.
- Redness at the vaginal opening and a ruptured hymen with old lacerations.
- A vaginal smear that tested negative for sperm.
The trial court considered these medical findings in its decision to convict Dadaeg.

Dadaeg's defense relied on an alibi, claiming he was at school during the time of the incident, supported by a student, Erlinda Cacatian.
The trial court found the alibi unconvincing, noting inconsistencies in Cacatian's testimony and her relationship with Dangan.
Dadaeg also suggested that the charges were motivated by revenge due to his assistance to a cultural minority in a land dispute.

The trial court found Dangan's testimony credible, highlighting her demeanor and the clarity of her account.
The defense's attempt to undermine Dangan's credibility by referencing prior "abuse" was countered by the court's interpretation that such admissions indicated non-consent.
The court also dismissed the defense's claims regarding the credibility of other witnesses, emphasizing the lack of substantial evidence supporting the alibi.

The court reiterated that the absence of sperm does not negate the possibility of rape, as established in previous cases.
The argument regarding the age of t...continue reading