Title
People vs. Domingo y Labis
Case
G.R. No. 225743
Decision Date
Jun 7, 2017
Accused abducted victim using a bladed weapon, raped her multiple times; claimed consensual relationship. Convicted of simple rape, reclusion perpetua imposed.
A

Case Summary (G.R. No. 225743)

Facts of the Case

On January 26, 2004, an Information was filed against the appellant for forcibly abducting AAA with intent to commit rape. The events occurred between January 24 and 25, 2004, in Rosario, Cavite. During the initial hearing on March 2, 2004, the accused was arraigned, entered a plea of not guilty, and a trial commenced. The prosecution's case included testimonies from AAA, police officer SPO3 Felipe Gomez, Jr., and a civilian, Elmer Marquez, while the defense called Sandy Domingo and a witness, Jocelyn Mariano.

Prosecution's Version of Events

AAA testified that on January 24, 2004, while waiting to be fetched by her cousin, she was approached by the appellant, who worked in a nearby fish stall. Approving the appellant's offer to accompany her home, they took a tricycle. As they traveled, the appellant brandished a bladed weapon, leading AAA to fearfully comply with his demands. They ultimately arrived at an unfamiliar location, after which the appellant forcedAAA into a house. He threatened her with the knife throughout the ordeal, ultimately raping her against her will several times before allowing her to leave around 3:00 AM to report the incident.

Defense's Version of Events

The defense contended that AAA was the appellant's girlfriend, suggesting that their relationship was consensual and that they had eloped to stay at his brother-in-law's home before returning to AAA's aunt's house. The appellant claimed he ran away from the scene after being chased by a man with a bolo knife, maintaining that he did not commit the alleged crime.

RTC's Decision

On September 6, 2013, the RTC found the accused guilty of forcible abduction with rape, imposing the penalty of reclusion perpetua. The court ordered him to pay AAA civil indemnity and moral damages.

CA's Decision

The CA, on September 24, 2015, affirmed the RTC's decision, noting that AAA's testimony was credible and conclusive. The CA emphasized that AAA’s failure to shout for help or resist physically did not equate to consent, particularly given the threat posed by the appellant with a blade. It rejected the argument of an uncorroborated testimony, concluding that medical evidence was not necessary for a conviction.

Issue on Appeal

The appellant argued that the prosecution failed to prove his guilt beyond a reasonable doubt, asserting AAA’s testimony lacked credibility and coherence. He contested the absence of the examining physician and noted that his romantic relationship with AAA undermined the prosecution's claims.

Supreme Court's Ruling

The Supreme Court affirmed the CA decision but modified the characterization of the crime. It held that the elements of forcible abduction were present; however, since the appellant's real intent w

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