Case Summary (G.R. No. 93709)
Charges and Allegations
Joseph Rabanes was charged with the crime of rape based on a sworn complaint filed by Angelina Naallatan on October 26, 1989. The information stated that on September 15, 1989, Rabanes, through force and intimidation, successfully had carnal knowledge of Naallatan against her will, in violation of Article 335 of the Revised Penal Code.
Proceedings and Evidence
During the trial, both parties presented evidence. The prosecution's account detailed that on September 15, 1989, Naallatan, while returning from her brother-in-law's house, was accosted by Rabanes. He reportedly threatened her with violence, causing her to lose consciousness, after which he raped her. Naallatan testified that she regained consciousness to find Rabanes assaulting her. Evidence included her torn clothing and medical examinations showing bruises and abrasions that corroborated her claims.
Witness Testimonies
Several witnesses supported Naallatan's testimony, including:
- Belen Paclar, Naallatan's sister-in-law, who observed her distressed state and helped report the crime.
- Barangay Kagawad Roman Ibajay, who confirmed Naallatan's testimony regarding her appearance post-incident.
- Felicito Cabasan, who saw Rabanes attacking Naallatan and heard her cries for help.
Defense and Counterarguments
Rabanes testified that his relationship with Naallatan was consensual, claiming they engaged in sexual acts for a fee, which she allegedly agreed to. However, his account faced scrutiny due to its implausibility, especially considering Naallatan's immediate report to her relatives and her desperate state upon arrival.
Trial Court's Decision
On May 9, 1990, the trial court found Rabanes guilty of rape and sentenced him to reclusion perpetua, along with ordering him to pay damages to Naallatan for moral damages, exemplary damages, and litigation expenses.
Appeals and Assignments of Error
Rabanes appealed the conviction, asserting:
- The trial court erred in finding that he used force and intimidation.
- The court credited Naallatan's inconsistent testimony.
- The consideration of his previous criminal case was unjustified.
- His intoxication should have been regarded as a mitigating factor.
Analysis of the Appeal
The appellate court dismissed Rabanes' claims. It upheld the trial court’s findings regarding the use of force, noting that injuries corroborated Naallatan's narrative. The absence of facial injuries did not undermine the credibility of her account or the occurrence of rape, as demonstrated in precedents that do not require physical signs for conviction. The appellate court also found no merit in the supposed inconsistencies in testimony, noting that they did not detract from the overall credibility of the victim.
Previous Criminal Record and Intoxicatio
...continue readingCase Syllabus (G.R. No. 93709)
Case Overview
- The case involves the criminal charge of rape against Joseph Rabanes, also known as "Bado," filed by the offended party, Angelina M. Naallatan.
- The information was filed on October 26, 1989, alleging that the crime occurred on September 15, 1989, in Sitio Cabiao, Barangay Luyong Bonbon, Municipality of Opol, Province of Misamis Oriental.
- Rabanes pleaded not guilty during his arraignment, initiating a trial where both parties presented evidence.
Prosecution's Case
- Angelina Naallatan, a 26-year-old housewife with two children, described the incident as a horrifying experience instead of a joyous birthday celebration for her daughter.
- On the day of the incident, while walking home to prepare for her daughter's birthday, she encountered Rabanes, who approached her aggressively.
- Rabanes slapped her, threatened her with a stone, and succeeded in raping her after she lost consciousness from his assaults.
- Angelina reported the crime to her sister-in-law, Belen Paclar, who then assisted her in seeking help from local authorities.
- Evidence presented included Angelina's torn clothing, testimonies of witnesses, and medical examinations that corroborated her account of the assault.
Witness Testimonies
- Belen Paclar observed Angelina's distressed condition upon her arrival, noting her pale appearance and bruises.
- Barangay Kagawad Roman Ibajay confirmed that he was informed of the incident and facilitated the arrest of Rabanes.
- Felicito Cabasan, a 13-year-old boy, testified that he saw Rabanes at