Case Summary (A.C. No. 13035)
Applicable Law
The relevant legal framework applicable for this decision is anchored in the 1987 Philippine Constitution and provisions under the Revised Penal Code regarding the crimes of forcible abduction and rape.
Factual Background
On May 28, 1972, Adelaida Vicario went to the poblacion of Capul with her fiancé, Macario Castillo, and her mother to have her wedding dress sewn. After having her measurements taken by seamstress Marcelina Magloyoan, Adelaida and her companions were attacked by Arcito Magdaraog, who forcibly abducted her at gunpoint while threatening Diena Castillo with a revolver. He dragged her to the seashore, then to Mrs. Maria Manaog's house, where he raped her despite her resistance and pleas. The following morning, Adelaida escaped and reported the incident to her father.
Medical Evidence
Adelaida underwent a medical examination by Dr. Conchita O. Tomada, who found fresh lacerations in her vagina and abrasions on her feet. The examination confirmed she suffered from physical pain consistent with her testimony regarding the assault.
Complainant’s Response and Reporting
Adelaida promptly went to the Fiscal's office to file a complaint against Magdaraog. She executed a letter-complaint and was assisted by Diena Castillo, who corroborated her claims. This swift action illustrates her intention to seek justice rather than imply any form of consent.
Defendant’s Assertion of Consent
Magdaraog admitted to having sexual intercourse with Adelaida but claimed it was consensual. He presented evidence of a prior romantic relationship with her, suggesting they planned to elope. However, this claim was significantly disputed by Adelaida’s testimony, which depicted a forcible abduction with no youthful elopement as asserted by the appellant.
Trial Court's Findings
The trial court rendered a verdict of guilt, expressing disbelief in the appellant's defense, which it viewed as fabricated to evade accountability. The court underscored that the serious nature of the charges warranted a stringent approach, especially given that Magdaraog utilized his position as a police officer to commit the abduction and rape.
Credibility Assessment
The court emphasized the credibility of Adelaida, noting that her prompt reporting of the crime lessened the potential for any alleged consensual narrative advanced by Magdaraog. The established presumption that a woman of decent repute would not falsely claim such a severe injustice provided further corroboration of her account.
Appeal and Affirmation of Decision
In the appeal, Magdaraog continued to claim that the act was consensual and that the charges stemmed from external pressures. Nonetheless, the appellate court affirmed the trial court's verdict, recognizing the deeply compelling evidence supporting the complainant's experience and the gravity of Magdaraog’s abuse
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Case Overview
- The case is an appeal from a decision rendered by the Court of First Instance of Northern Samar on May 28, 1975.
- The appellant, Arcito Magdaraog, was found guilty of Forcible Abduction with Rape and sentenced to reclusion perpetua.
- He was ordered to indemnify the offended party, Adelaida Vicario, P3,000 and her parents P2,000, along with costs.
Facts of the Case
- On May 28, 1972, Adelaida Vicario, her fiancé Macario Castillo, and her mother visited Capul for wedding preparations.
- Adelaida visited the seamstress, Marcelina Magloyoan, to have her wedding dress made.
- Afterward, as they were returning home, the accused, Arcito Magdaraog, confronted them with a revolver, forcibly taking Adelaida away.
- Despite Adelaida's resistance and protests, Arcito forcibly dragged her towards the seashore and eventually to the house of Mrs. Maria Manaog.
- Inside the house, he overpowered her and committed sexual assault, which included penetration.
- The following morning, Adelaida managed to escape and immediately sought medical attention.
Medical Examination
- Adelaida was examined by Dr. Conchita O. Tomada, who found fresh lacerations and abrasions, confirming the assault.
- A medical certificate was issued, noting injuries consistent with rape.
Timeline of Events
- Adela