Case Summary (G.R. No. 229677)
Allegations of Non-Consensual Acts
AAA claimed XXX drugged her by placing a noxious hand over her nose, locked her in his room, then twice had non‐consensual intercourse by force, intimidation, and with a firearm, inflicting pain and fear.
Testimonies of Complainant’s Mother and Sister
BBB testified she discovered her daughter locked in XXX’s room on October 18, 2000, after knocking repeatedly; she escorted AAA home without any disclosure of rape. CCC recounted that XXX visited their home on October 20 to propose, and AAA had forewarned her not to believe claims of a romantic relationship.
Medical Examination
Dr. Legaspi found old healed hymenal lacerations on AAA that could result from prior consensual or accidental causes. No acute injuries consistent with forcible rape were recorded.
Defense Version and Exculpatory Evidence
XXX maintained a consensual sweetheart relationship: he and AAA had intimate relations twice; AAA wrote affectionate notes on a Jollibee napkin and a photograph; XXX left her undergarments, a ring, and money when she left his apartment; DDD observed them together daily, caressing, watching television side by side with the door open, and going to the market arm-in-arm.
RTC Decision
By joint decision dated November 24, 2011, the trial court found XXX guilty of two counts of rape under Article 266‐A(a) RPC and sentenced him to reclusion perpetua with indemnities and damages for AAA.
Court of Appeals Ruling
By decision dated September 27, 2016, the Court of Appeals affirmed the conviction, adjusting damages per People v. Frias: P50,000 moral, P50,000 civil indemnity, P30,000 exemplary per count, but denied XXX’s claim of consensual intercourse.
Issue on Appeal to the Supreme Court
Whether force or intimidation was proven beyond reasonable doubt to overcome XXX’s presumption of innocence and to differentiate non-consensual rape from consensual intercourse among lovers.
Applicable Constitutional and Penal Provisions
Under the 1987 Constitution, accused enjoys presumption of innocence and right to due process. Rape under Article 266‐A(1)(a) requires proof of carnal knowledge by force, threat, or intimidation.
Supreme Court’s Credibility Analysis
The Court scrutinized AAA’s testimony and found material inconsistencies and improbabilities: contradictory statements on whether the door was locked, failure to call for help despite open windows, and unnatural delay in reporting to her mother.
Contradictions in Witness Statements
BBB’s testimony that she freely opened XXX’s room door on October 18 directly contradicted AAA’s claim of being locked up. CCC’s account of a peaceful proposal visit further undermined the claim of confinement and terror.
Evidence
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Background and Parties
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: XXX
- Private complainant: AAA (name initials per A.C. 83-2015)
- Other prosecution witnesses: BBB (mother of AAA), CCC (sister of AAA), Dr. Angelita C. Legaspi (Rural Health Physician)
- Defense witness: DDD (neighbor of XXX)
Facts of the Case
- February 2000: AAA first meets XXX in a Calapan City restaurant where she worked.
- October 9 & 13, 2000: XXX courts AAA at an appliance store; offers her a spare room for rent.
- October 13, 2000 (night): AAA moves into XXX’s two-storey apartment, room adjacent to his.
- October 16, 2000 (evening): AAA’s parents visit; share drinks with XXX; AAA and her mother sleep in XXX’s room.
- October 17, 2000 (09:00 AM): Parents leave; XXX allegedly holds AAA, covers her nose with his hand, forcibly removes her undergarments, and has non-consensual intercourse.
- October 17, 2000 (02:00 PM): XXX returns, threatens AAA with a firearm, forces her to submit to a second assault, then warns her not to tell anyone and locks the door.
- October 18, 2000: BBB rescues AAA from the locked room but AAA cannot bring herself to speak of the incident until October 19.
- October 20 & 23, 2000: AAA and BBB report the alleged assaults to police; XXX appears at AAA’s home and proposes marriage, which AAA rejects.
Procedural History
- Two separate Informations filed under Article 335 RPC in relation to R.A. 7659 & 8353:
• Crim. Case No. C-6350 (first rape count)
• Crim. Case No. C-6358 (second rape count) - Trial Court (RTC Branch 40, Calapan City): arraignment, not guilty plea; prosecution and defense witnesses heard; exhibits admitted.
- Trial Court Decision (Nov. 24, 2011): conviction for two counts of rape under Article 266-A(a) RPC; sentenced to two (2) reclusion pe