Title
People vs. Savellano
Case
G.R. No. L-31227
Decision Date
May 31, 1974
A 17-year-old girl, Zosima, was raped by Antonio Savellano, who overpowered her despite her resistance. The Supreme Court upheld his conviction, affirming the credibility of her testimony and the sufficiency of evidence proving force.

Case Summary (G.R. No. L-17451)

Charges and Penalty

Savellano was charged with the crime of rape and subsequently convicted, receiving a sentence of reclusion perpetua, along with an order to indemnify Zosima in the amount of ten thousand pesos.

Incident Details

On the morning of July 18, 1969, Zosima was sent by her mother to run an errand to her elder sister's house. During her journey, she was ambushed by Savellano, who physically overpowered her despite her resistance, which included kicking and scratching him. Savellano managed to force her to the ground and proceeded to have sexual intercourse with her. Following the act, he threatened her against disclosing the incident.

Reaction and Reporting

After the assault, Zosima returned to her sister’s house, visibly distressed, and informed her brother-in-law about the incident, expressing her desire to retaliate against Savellano. With guidance from her family, they reported the incident to the local authorities instead of taking matters into their own hands, which was a conscious decision to avoid familial retribution.

Arrest and Investigation

Savellano was arrested later that same day. Subsequent medical examinations conducted on both Zosima and Savellano provided evidence supporting the claim of rape. Although no distinct signs of recent injury were found on Zosima, medical testimony indicated that her hymen had been ruptured, while Savellano had several scratches, likely resulting from Zosima's struggle during the assault.

Legal Proceedings

A verified complaint for rape was filed by Zosima in the relevant municipal court on July 23, 1969. Importantly, Savellano’s argument questioning the jurisdiction of the trial court was rejected; the court found that Zosima’s complaint had indeed been properly filed, which allowed jurisdiction to be established.

Credibility of Testimonies

The trial saw conflicting narratives between Savellano and Zosima regarding their relationship. Savellano claimed they had been sweethearts and engaged in consensual sexual activities prior to the incident. However, the trial court found significant inconsistencies in Savellano's testimony. Savellano’s assertion was deemed implausible given the context and nature of the assault, as well as Zosima's immediate reporting of the crime rather than remaining silent, which is often the reaction associated with consensual encounters.

Court’s Assessment

The trial court emphasized that the nature of force used in a rape case does not necessitate extreme violence but must be sufficient to allow for the act to occur. The court also considered the physical disparity between the victi

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