Title
People vs. Villorente
Case
G.R. No. 100198
Decision Date
Jul 1, 1992
Accused-appellants abducted and raped Jona Neron through deception and threats; Supreme Court upheld their conviction, affirming complex crime of abduction with rape, with reclusion perpetua for Charlie and clemency recommended for Teresita.

Case Summary (G.R. No. 228232)

Summary of Facts

The information filed against the accused indicated that on March 25, 1986, they abducted Jona Neron, who was an employee in the household of Claire Tioco. The execution of the abduction involved deceit, as Teresita Villorente misrepresented herself as Jona's mother and claimed that Jona's father was ill. This manipulation led Jona to leave with the accused, who then took her to their residence, where she was subsequently raped by Charlie Villorente.

Witness Testimonies and Evidence

The prosecution presented five witnesses. Claire Tioco testified to the initial visit of Charlie Villorente on March 15, 1986, and the suspicious circumstances surrounding Jona's departure on March 25. Jona Neron recounted her experience of being taken against her will and enduring multiple instances of sexual abuse. Notably, she described being threatened with a bolo by Charlie, which instilled fear and prevented her from escaping or calling for help. Dr. Emily Bacolod’s medical examination of Jona revealed old lacerations consistent with recent sexual intercourse.

Defense Assertions

The defense called only Teresita Villorente to testify, who claimed to have been in Manila during the events in question, presenting an inconsistent narrative. Charlie Villorente did not testify, despite several opportunities. The defense argued against the credibility of Jona’s testimony, suggesting that her failure to call for assistance during the alleged rapes diminished the believability of her claims.

Court Findings and Rulings

In its judgment, the trial court found substantial credibility in the testimonies provided by the victim and supporting witnesses, observing that Jona’s demeanor was consistent and straightforward under examination. The court emphasized that the mere presence of others in the household did not negate the possibility of rape. The findings reinforced the assertion that the crime committed was a complex crime of abduction with rape, leading to the conviction of both appellants with a penalty of reclusion perpetua and the requirement to indemnify Jona Neron.

Legal Considerations

The court highlighted that consent could not be considered valid due to the victim's age (fifteen at the time) and the coercive circumstances surrounding the sexual acts. It recognized that the abduction was necessary for the commission of rape, thereby establishing a strong nexus between the two offenses under Article 48 of the Revised Penal Code.

App

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