G.R. No. 139338 ; May 28, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LITO EGAN alias AKIAO, accused-appellant.

FACTS

On January 6, 1997, accused-appellant Lito Egan, a 36-year-old Manobo, forcibly abducted 12-year-old Lenie Camad while she was fetching water. He dragged her away at knifepoint, threatening to kill her if she resisted, and brought her to different locations in Cotabato and Bukidnon over several months. Lenie testified that Egan raped her during this period. Her father, Palmones, immediately searched for her with the help of village datus, who attempted a customary settlement. Egan allegedly agreed to give two horses as dowry (bagay) for marriage but reneged. After failed negotiations, Lenie was rescued on May 15, 1997, and a case for forcible abduction with rape was filed.
Egan claimed he and Lenie were living together as husband and wife under Manobo custom since September 1996 after he gave a dowry to her family. He asserted that Lenie voluntarily accompanied him to capture a wild horse demanded by her father and that the criminal charge arose only when he failed to deliver two horses. He presented a letter to support his claim of a marital arrangement and argued Lenie never attempted to escape during their travels through populated areas.

ISSUE

Whether the trial court correctly convicted Lito Egan of the complex crime of forcible abduction with rape.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the prosecution’s evidence credible and consistent, establishing all elements of forcible abduction: (1) the victim was a woman; (2) she was taken against her will; and (3) the abduction was with lewd designs. Lenie’s young age and Egan’s use of a knife and death threats clearly proved the taking was forcible and against her will. Her credible testimony, coupled with the medico-legal findings, substantiated the rape. The Court rejected Egan’s defense of a pre-existing marital arrangement. His claim of giving a dowry in 1996 was uncorroborated and belied by the immediate search and abduction report. The purported letter was deemed a self-serving fabrication. The Court also noted that the victim’s failure to escape from populated areas did not negate abduction, as the initial taking was forcible and her continued fear was reasonable given the threats. The complex crime of forcible abduction with rape was properly appreciated, as the abduction was a necessary means to commit the rape. The penalty of reclusion perpetua and awards of damages were affirmed.