People v. Laray

G.R. No. 101809 (February 20, 1996)

Facts:

On the evening of July 27, 1989, Hilda Jamis was at a benefit dance in Tangcob, Libertad, Misamis Oriental, when she was approached by Roger Laray, who grabbed her hand and pulled her away from her seat. He took her to a secluded area where he, along with four other men—Rewel Rabanes, Noli Enerio, Federico Laray, and Gorospe Omilao—held her down and stripped her of her clothing. Roger Laray then physically assaulted Hilda, causing her to lose consciousness, after which he raped her. Following this, the other men took turns raping her while she was restrained.

In defense, Roger Laray claimed that he and Hilda were sweethearts and that their sexual encounter was consensual. He recounted that they had previously engaged in consensual sexual relations and that they had gone to an uninhabited house together that night. The other accused men provided alibis, asserting they were elsewhere during the incident.

The prosecution presented medical evidence showing multiple abrasions on Hilda's body, consistent with her account of being raped. The trial court found all five accused guilty of multiple rape, sentencing them to reclusion perpetua and ordering them to pay Hilda damages.

Legal Issues:

1. Whether the sexual intercourse between Roger Laray and Hilda Jamis was consensual, given Laray's claim of a romantic relationship.
2. Whether the testimonies of the accused, particularly their alibis, could outweigh the positive identification and account of the victim, Hilda Jamis.

Arguments:

• Prosecution's Argument:

  • Hilda Jamis's testimony was consistent and corroborated by medical evidence of physical injuries.
  • The claim of a romantic relationship was unsubstantiated, lacking evidence such as love notes or photographs.
  • The presence of multiple assailants and the use of force negated any claim of consent.

• Defense's Argument:

  • Roger Laray argued that he and Hilda were sweethearts, asserting that their encounter was consensual.
  • The other accused provided alibis, claiming they were not present at the scene of the crime.
  • The defense pointed out inconsistencies in Hilda's testimony, suggesting that her account was unreliable.

Court's Decision and Legal Reasoning:

The court upheld the conviction of Roger Laray and Noli Enerio, finding that the evidence presented by the prosecution was credible and compelling. The court rejected the defense's claim of a romantic relationship, noting the lack of substantial evidence to support it. The court emphasized that even if a romantic relationship existed, it did not justify the use of force or violence in sexual encounters.

However, the court found reasonable doubt regarding the involvement of Rewel Rabanes, Federico Laray, and Gorospe Omilao. The court noted that Hilda's identification of these men was weak, as she had not known them prior to the incident and had only identified them by their names during the assault. The court ruled that the prosecution failed to meet the burden of proof beyond a reasonable doubt for these three accused.

Significant Legal Principles Established:

1. Consent in Rape Cases: The court reiterated that consent cannot be presumed based on a prior romantic relationship. A person cannot be forced to engage in sexual acts against their will, regardless of their relationship status.
2. Credibility of Witnesses: The court acknowledged that minor inconsistencies in a victim's testimony do not necessarily undermine their credibility, especially in cases involving traumatic experiences.
3. Burden of Proof: The prosecution bears the burden of proving the guilt of the accused beyond a reasonable doubt. In cases where the evidence is weak, the defense of alibi can gain significance.