Case Summary (G.R. No. 214407)
Factual Background
The events of June 9, 1971, commenced when Esther boarded a jeepney in Caloocan City bound for Manila. Inside, she encountered Pena, who threatened her with a gun and directed the driver to travel to locations including Baclaran and finally to an isolated hut near Manila Bay, where she was allegedly raped. Esther testified that Pena exerted threats and violence, leading to her sexual assault. She was held at a separate location for days and was later able to contact her mother, who, along with police, ultimately rescued her.
Procedural History
Pena was charged with the crime of forcible abduction with rape in the Court of First Instance of Manila, following Esther's sworn complaint. The trial court found him guilty solely of rape, sentencing him to reclusion perpetua but failing to impose an indemnity.
Key Evidence
The prosecution's case relied heavily on Pena's extrajudicial confession and the testimony of the complainant. The confession revealed that Pena admitted to using threats to compel Esther to engage in sexual intercourse. Medical examinations corroborated that Esther had been raped, showing signs of recent sexual activity and physical injury consistent with her testimony.
Legal Issues Raised
Pena contested the admissibility of his extrajudicial confession, arguing that it had been obtained under duress, citing mistreatment by police. The trial court, however, found no evidence of coercion, and the confession was deemed voluntary. Pena also disputed the credibility of Esther's testimony and the presence of weapons during the incident.
Findings on Credibility and Guilt
The trial court evaluated the testimonies presented, ultimately finding Esther's account credible while dismissing Pena's conflicting narrative as implausible and self-serving. The court also noted the psychological impact on Esther during her testimonies, demonstrating her genuine fear and the traumatic nature of the events.
Jurisdictional Considerations
The court established its jurisdiction over the case based on the transitory nature of the crime, given that part of the alleged abduction began in Manila. Although forcible abduction was not proven, the court maintained jurisdiction in convicting Pena for the act of rape.
Sentence and Indemnity Implications
The court sentenced Pena to reclusion perpetua as dictated by the law due to the nature of the crime, specifica
...continue readingCase Syllabus (G.R. No. 214407)
Case Background
- This case involves accusations against Rolando Pena for forcible abduction with rape.
- The trial court convicted Pena solely of rape, ruling that forcible abduction was not proven due to the absence of lewd designs in the complainant's taking.
- The complainant, Esther Tayag, was abducted from Ocampo Street, Caloocan City, and taken to an isolated hut in Manila Bay near Lido Beach, Cavite, where the alleged rape occurred.
Parties Involved
- Accused: Rolando Pena, 28 years old, single, a security guard at Hercon Security Agency, residing in Tondo, Manila.
- Complainant: Esther Tayag, 23 years old, single, a sales girl at Shelton Department Store in Quiapo, Manila.
Nature of the Relationship
- Esther and Rolando were introduced by a mutual friend, Oscar, in April 1971.
- Pena professed a deep love for Esther, claiming he was prepared to marry her, although they were not in a romantic relationship.
Details of the Incident
- On June 9, 1971, Esther boarded a jeepney for work, where she encountered Pena, who threatened her with a gun.
- Pena directed the jeepney driver to Baclaran instead of stopping at Quiapo, eventually leading to an isolated area where he forced her into a boat.
- After arriving at a hut in the bay, Pena threatened Esther with a knife and coerced her into sexual intercourse, which she resisted initially but eventually succu