Case Summary (G.R. No. 151993)
Facts of the Case
On March 18, 1982, Nenita Obogne reported that she was forced by Graciano Geneveza, who threatened her with a knife, to a secluded house, where she was raped twice. The incident was reported to the police four months later, on August 5, 1982, following confirmation of her pregnancy at San Lazaro Hospital.
Testimonies of the Parties
Nenita Obogne claimed that Geneveza undressed her and forcibly had sexual intercourse with her, citing fear as the reason for her lack of resistance. In contrast, Graciano Geneveza asserted that the encounter was consensual, stating that they had a romantic relationship and that Nenita willingly accompanied him to the house of Melanio Antipuesto.
Defense and Supporting Witnesses
The defense presented Buenaventura Santos, Jr., who corroborated Geneveza’s account, describing the events leading up to the meeting with Nenita as friendly and consensual. Santos indicated that Geneveza and Nenita appeared to be in a romantic mood, lending weight to the defense argument of consensual interaction.
Trial Court Decision
On December 13, 1985, the trial court convicted Geneveza based on the strength of Obogne's testimony, which the court deemed credible. He was sentenced to reclusion perpetua.
Appeal and Arguments Raised
Geneveza appealed the conviction, raising multiple errors by the trial court. He contested the credibility of Obogne's testimony, the dismissal of his defense, the corroborative nature of Santos' testimony, and the significant delay in reporting the alleged crime, which he claimed affected the reliability of the complainant’s account.
Credibility of the Complainant
In assessing the appeal, the Supreme Court emphasized the significant importance of the complainant's credibility in rape cases. It noted contradictions in Obogne’s testimony regarding her familiarity with Geneveza and inconsistencies concerning her state of mind during the alleged assault.
Supreme Court's Analysis
The Court observed that the prosecution’s burden is to establish beyond a reasonable doubt that the crime of rape occurred. It defined rape under Article 335 of the Revised Penal Code and scrutinized whether the requisite element of force or intimidation was adequately de
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Case Background
- The case is an appeal from the decision of the Regional Trial Court of Malabon, Metro Manila, Branch CLXIX, convicting Graciano Geneveza of the crime of rape.
- The trial court sentenced Geneveza to reclusion perpetua.
- Upon arraignment, the accused pleaded not guilty.
Factual Summary
- Complainant: Nenita Obogne, a resident of Caloocan City, reported the incident on August 5, 1982, claiming she was raped by the accused on March 18, 1982.
- Incident Details:
- On the night of the incident, Nenita was approached by Geneveza, who allegedly threatened her with a knife.
- She was taken to a house owned by Melanio Antipuesto, where she was undressed and raped twice by Geneveza.
- Nenita reported feeling afraid and did not resist during the act.
- She became pregnant as a result of the encounter and later gave birth to twins.
Defendant's Version
- Accused's testimony: Graciano Geneveza claimed that he and Nenita had a consensual relationship.
- He testified that they agreed to go for a walk after meeting casually and that any intimacy was voluntary.
- Defense Witness: Buenaventura Santos, Jr. corroborated Geneveza's version, stating he saw them together and perceived their interaction as romantic.
Trial Court's Decision
- Th