People v. Andres
G.R. No. 114936 (February 20, 1996)
Facts:
Appellant Romy Andres was charged with the crime of rape in four separate complaints filed by Ruwerose A. Corpuz, which were consolidated and tried together in the Regional Trial Court of Bangui, Ilocos Norte. The incidents were alleged to have occurred on four different occasions: the first in February 1988, the second also in February 1988, the third in April 1989, and the last on May 10, 1989. During the arraignment on July 12, 1989, the appellant pleaded "not guilty" to all charges.
On September 28, 1993, the trial court acquitted the appellant in three of the four cases (Criminal Cases No. 777-19, 778-19, and 779-19) due to the prosecution's failure to prove guilt beyond a reasonable doubt. However, in Criminal Case No. 776-19, the court found him guilty of rape as defined under paragraph (3) of Article 335 of the Revised Penal Code, imposing the penalty of reclusion perpetua and ordering him to pay moral damages to the complainant.
The prosecution's case relied heavily on the testimony of the complainant, who recounted that in February 1988, while attempting to retrieve vegetables from their old house, she was accosted by the appellant, who was armed with a knife. Despite her struggles and attempts to shout, the appellant forcibly removed her clothing and raped her. After the assault, he threatened her not to tell anyone about the incident. The complainant later confided in her grandmother, but the matter was not reported until May 10, 1989, when her mother learned of the assaults and reported it to the police.
The appellant denied the allegations, admitting to having sexual intercourse with the complainant on two occasions in 1989 but claiming that it was consensual, asserting that they were lovers.
Legal Issues:
The primary legal issue in this case was whether the trial court erred in finding the appellant guilty of rape despite the appellant's claim of implied consent from the complainant. The case also raised questions regarding the application of statutory rape laws, particularly concerning the age of the complainant and the nature of consent.
Arguments:
The prosecution argued that the complainant's testimony was credible and corroborated by a medico-legal report, which indicated evidence of penetration. They emphasized that the complainant was only eleven years old at the time of the first incident, and under the law, a minor below twelve years old cannot give valid consent to sexual acts.
The appellant contended that the trial court erred in its conviction, asserting that the complainant's failure to resist his advances indicated consent. He argued that the relationship between him and the complainant was one of mutual affection, which negated the claim of rape.
Court's Decision and Legal Reasoning:
The court affirmed the trial court's decision, emphasizing that the appellant's conviction was based on the statutory rape provisions of the Revised Penal Code. The court noted that under Article 335, consent is immaterial when the victim is below twelve years of age. The mere act of having sexual relations with a girl under this age constitutes rape, regardless of any perceived consent.
The court found the complainant's testimony to be credible and consistent, supported by the medico-legal report that indicated signs of sexual assault. The court dismissed the appellant's argument regarding implied consent, reiterating that the law presumes that a child below twelve cannot give intelligent consent to sexual acts.
Significant Legal Principles Established:
Statutory Rape: The case reaffirmed the principle that in statutory rape cases, the age of the victim is a critical factor, and consent is irrelevant if the victim is below the statutory age.
Credibility of Victim's Testimony: The court highlighted the importance of the victim's testimony, especially in cases involving minors, and the presumption against fabrication of such serious allegations by young victims.
Legal Presumption of Non-Consent: The ruling established that the law presumes non-consent in cases involving minors, thereby protecting vulnerable individuals from exploitation.