G.R. No. 125537 March 8, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSE MAGLANTAY Y DEO, accused-appellant.

FACTS

On May 8, 1994, after a company excursion, complainant Lea Ubaldo was at the Lowell Building in Quezon City. As she was about to leave, accused-appellant Jose Maglantay blocked her, held her hands, and forcibly kissed her. Despite her struggles, he dragged her to the second floor. They encountered Mary Ann Robencio, whom Maglantay warned not to interfere. He then laid Ubaldo on the floor, raised her shirt, pulled down her shorts and panty, and had carnal knowledge against her will. He then forced her into a comfort room where he raped her a second time. Security guard Alfonso Javier, alerted by the commotion and fearing Maglantay who was known to be violent, called the police. Upon arrival, they found Ubaldo’s belongings scattered, drops of blood in the corridor, and Ubaldo emerging from the comfort room crying, with blood on her thighs, and immediately seeking help. A medical examination later confirmed contusions and abrasions on her body.
The accused-appellant admitted to sexual intercourse but claimed it was consensual, alleging he and Ubaldo were lovers. He asserted they went to the comfort room to be intimate, and her injuries were sustained when they accidentally slipped on a toilet plunger. He argued her immediate report to authorities was inconsistent with a romantic relationship.

ISSUE

Whether the accused-appellant is guilty beyond reasonable doubt of the crime of rape.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the prosecution’s evidence, comprising the credible and consistent testimonies of Ubaldo, eyewitness Robencio, and security guard Javier, along with the physical evidence and medical findings, sufficient to prove guilt beyond reasonable doubt. The defense of consensual sex was rejected as inherently unbelievable. The Court noted that the claim of a romantic tryst in a comfort room defied common experience and human behavior. Ubaldo’s immediate outcry, her distressed physical state upon discovery, and her prompt pursuit of medical and legal action were utterly inconsistent with consent. The sweetheart defense, often invoked in rape cases, was deemed a fabrication that failed to overcome the clear demonstration of force and lack of consent. The trial court’s factual findings, which hinged on credibility, were accorded finality. The penalty of reclusion perpetua was affirmed, and accused-appellant was ordered to pay the victim P50,000.00 as civil indemnity and P50,000.00 as moral damages.