Case Summary (G.R. No. 240662)
Key Dates
• April 2, 2015 – Alleged commission of rape
• January 29, 2016 – RTC conviction and sentence
• February 7, 2018 – Court of Appeals (CA) affirmation and damage awards
• September 16, 2020 – Supreme Court decision
Applicable Law
• 1987 Philippine Constitution – presumption of innocence; burden of proof beyond reasonable doubt
• Revised Penal Code, Article 266-A (as amended by R.A. 8353) – elements and penalties for rape
Charge and Trial Record
The accused was charged under Article 266-A(1)(a) RPC for having carnal knowledge of AAA through force, threat, and intimidation. At trial, the complainant testified that appellant pointed a deadly weapon at her, stripped her, threatened to kill her and her mother, and sexually penetrated her without consent. A medico-legal examination by Dr. Cornelio revealed deep healed hymenal lacerations and recent blunt penetrating trauma. Appellant denied the allegations, alleging a false complaint motivated by a refusal to lend money. Character witnesses for the defense attested to his good reputation and existing live-in partner.
RTC Findings and Sentence
The trial court found the complainant credible, treated inconsistencies in minor details as badges of truth, and held that appellant, as a close relative, exercised moral ascendancy over a partly illiterate but adult victim. He was convicted of rape, sentenced to reclusion perpetua without parole, and ordered to pay indemnity and moral damages of ₱50,000 each.
Court of Appeals Ruling
The CA affirmed the conviction but increased civil indemnity and moral damages to ₱75,000 each and added exemplary damages of ₱75,000, holding that complainant’s testimony and medico-legal findings sufficiently proved rape.
Issue on Further Appeal
Whether the CA erred in upholding the conviction for rape despite alleged deficiencies in proving force, threat, intimidation, or moral ascendancy beyond reasonable doubt.
Legal Framework for Rape Prosecutions
Under the 1987 Constitution, an accused is presumed innocent, and guilt must be established beyond reasonable doubt. Rape under Article 266-A(1)(a) requires proof of (1) carnal knowledge of a woman by a man, and (2) accomplishment through force or intimidation, unconsciousness, or moral ascendancy. While a credible complainant’s testimony can suffice, it must itself be credible, reasonable, and internally consistent.
Supreme Court Analysis – Weapon and Threat Allegations
The complainant’s initial claim of a “deadly weapon” was never specified or mentioned again in detail. No testimony described the nature, use, or continuous presence of the weapon during the alleged rape. This unexplained disappearance undermines the credibility of the alleged threat and suggests fabrication intended to color the narrative of force.
Supreme Court Analysis – Force, Intimidation, and Moral Ascendancy
Intimidation must be viewed from the victim’s perception and must reach a degree that overcomes her free will. AAA was a physically capable 20-year-old without any clinical finding of mental impairment. The record lacks evidence of repeated or sustained threats, physical restraint beyond covering the mouth once, or any overt show of force. Appellant is a third-degree relative (mother’s cousin), not a close kin entitled to moral ascendancy presumption under existing jurisprudence, which applies only to minors or direct ascendant-descendant relationships.
Supreme Court Analysis – Post-Incident Conduct
Following the alleged assault, AAA voluntarily met appellant on multiple occasions: at a balete tree on April 3 (where she permitted affection and fondling), at the vulcanizing shop on April 4 (where she remained when doors were locked), and in Bacla
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Procedural History
- The Regional Trial Court (RTC), Branch 275, Las Piñas City, convicted appellant Raymundo Rapiz y Correa of simple rape under Article 266-A, paragraph 1(a) of the Revised Penal Code, as amended by RA 8353, sentencing him to reclusion perpetua and awarding AAA P50,000.00 for civil indemnity and P50,000.00 for moral damages.
- On appeal to the Court of Appeals (CA) in CA-G.R. CR HC No. 08109, the conviction was affirmed; civil indemnity and moral damages were increased to P75,000.00 each, and exemplary damages of P75,000.00 were awarded.
- Appellant petitioned the Supreme Court for review of the CA decision, adopting arguments previously raised before the CA.
Factual Background
- On or about April 2, 2015, in Las Piñas City, appellant allegedly threatened AAA with a deadly weapon, undressed her, and had carnal knowledge of her against her will.
- In succeeding days (April 3, 4, and 6, 2015), appellant and AAA spent time alone—under a balete tree, at a vulcanizing shop, and in Baclaran—where appellant hugged, kissed, fondled, and again inserted his penis into her vagina.
- On April 7, 2015, AAA’s mother, BBB, filed a barangay complaint based on a fight between AAA and appellant’s live-in partner; at the hearing, AAA disclosed three to four instances of forced intercourse.
Prosecution’s Evidence
- AAA testified that appellant pointed a weapon at her, covered her mouth with his hand, forced her onto a bed, removed her clothing one piece at a time, and inserted his penis into her vagina while threatening to kill her and her mother if she resisted or complained.
- At a subsequent barangay hearing, AAA repeated that appellant had raped her multiple times inside his house.
- Medico-legal Officer Dr. Reah Mangroba Cornelio found deep healed lacerations on AAA’s hymen at 3, 6, and 9 o’clock positions, concluding there was recent blunt penetrating trauma.
Defense’s Evidence
- Appellant denied any sexual contact, alleging BBB fabricated the rape charge after he refused to lend her ₱1,500 for travel.
- He claimed to have been working inside a vulcanizing shop eight meters from his house, where he also lived