People vs. Pasayan

G.R. No. 91619 (September 9, 1996)

Gavino L. Pasayan's rape conviction upheld; indemnity raised to P50,000 for credible victim testimony.

Facts:

On May 5, 1987, Gavino L. Pasayan was charged with the crime of rape against Dolores S. Catimbang. The incident occurred on April 8, 1987, at approximately 2:20 PM at the Garden Resort Inn in Calamba, Laguna. The Information alleged that Pasayan, with lewd design and through the use of force, threats, and intimidation, had carnal knowledge of Catimbang against her will.

Dolores Catimbang testified that she had known Pasayan since December 1986, as he was the driver for the company where she worked. On the day of the incident, Pasayan visited her at the office, pleading for her to act as a guarantor for a loan he needed. After some discussion, she agreed to have lunch with him. They went to a restaurant, where Pasayan insisted she drink a soft drink he had poured for her. After lunch, when Catimbang suggested returning to the office, Pasayan instead drove towards Calamba, claiming he needed to see a friend.

Catimbang began to feel dizzy and lost consciousness. When she regained her senses, she found herself naked in a room at the Garden Inn Resort, with Pasayan beside her. She noticed blood on the bedsheet and felt pain throughout her body. Pasayan threatened her with a knife, forcing her to submit to his advances. After the assault, he warned her not to tell anyone about the incident.

Catimbang managed to escape and sought refuge at a friend's house, where she remained until her parents found her on April 11, 1987. She reported the incident to the police and underwent a medical examination, which revealed injuries consistent with sexual assault.

The defense presented evidence claiming that Catimbang had willingly gone to the resort with Pasayan, asserting that they were in a romantic relationship. Pasayan admitted to having sexual intercourse with Catimbang but denied using force or intimidation. The defense also questioned the credibility of Catimbang's testimony and the medical findings.

Legal Issues:

  1. Whether the trial court erred in finding Pasayan guilty of rape beyond reasonable doubt.
  2. Whether the evidence presented by the prosecution sufficiently established the elements of rape, particularly the lack of consent and the use of force or intimidation.

Arguments:

Prosecution:

  • Catimbang's testimony was consistent and credible, detailing the events leading to the assault and the subsequent threats made by Pasayan.
  • Medical evidence corroborated Catimbang's claims of violence and sexual assault, showing injuries consistent with rape.
  • The prosecution argued that Catimbang's behavior after the incident was indicative of trauma and confusion, supporting her claims of being raped.

Defense:

  • Pasayan contended that Catimbang had willingly engaged in sexual relations with him, asserting that they were in a consensual relationship.
  • The defense questioned the credibility of Catimbang's testimony, suggesting inconsistencies and alleging that her injuries could have been inflicted by others.
  • They argued that the lack of medical evidence proving drugging or incapacitation undermined the prosecution's case.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding Pasayan guilty of rape. It held that the prosecution had established beyond reasonable doubt that Catimbang did not consent to the sexual act and that Pasayan used force and intimidation. The court emphasized the credibility of Catimbang's testimony, noting that her account was consistent and supported by medical evidence.

The court rejected the defense's arguments, stating that the mere existence of a prior relationship did not negate the possibility of rape. It also found that the injuries sustained by Catimbang were consistent with the violent nature of the assault, and the threats made by Pasayan were sufficient to establish the element of intimidation.

The court highlighted the principle that a victim's testimony in rape cases can be sufficient for conviction if it is credible and consistent with human experience. The court also noted that the accused's admission of having sexual intercourse with the victim further supported the prosecution's case.

In light of the extraordinary circumstances of the case, the court increased the indemnity to Catimbang from P25,000 to P50,000.

Significant Legal Principles Established:

  • The testimony of a rape victim can be sufficient for conviction if credible and consistent.
  • Prior relationships do not negate the possibility of rape if consent is not established.
  • The use of threats and intimidation can satisfy the elements of rape, even in the presence of a prior consensual relationship.