G.R. No. L-6868, December 14, 1911
THE UNITED STATES, plaintiff-appellee, vs. PEDRO IGLESIA and JUAN VALDEZ, defendants-appellants.

FACTS

On the evening of March 29, 1910, the accused Pedro Iglesia (armed with a revolver) and Juan Valdez went to the house of Santos Pascual. Pretending to be detectives, they demanded to see Pascual’s personal cedula. After taking possession of it, they compelled Pascual and his wife, Dorotea de la Cruz, to accompany them under the pretext of taking them to the town hall. Instead, they were taken to a remote and solitary spot called Nagtuturican. There, Pedro Iglesia first threatened Dorotea with the revolver, gagged her, and forcibly had sexual intercourse with her while Juan Valdez kept watch over the husband, Santos Pascual. Afterwards, Juan Valdez also forcibly had sexual intercourse with Dorotea. The accused were subsequently arrestedJuan Valdez near the railway station by the teniente del barrio, and Pedro Iglesia at Nagtuturican by the police.

ISSUE

Whether the evidence presented is sufficient to convict the accused of the crime of violación (rape) as charged.

RULING

Yes. The Supreme Court affirmed the conviction but modified the penalty. The Court agreed with the trial court’s factual findings, which established the guilt of the accused beyond reasonable doubt. However, it disagreed with the application of the extenuating circumstance of “race” under Article 11 of the Penal Code, finding that the accused were not entitled to it given the heinous nature of the crime. Furthermore, the Court added the aggravating circumstance of “ignominy” (ignominia) under Article 10, paragraph 12, because the crime was committed in a manner that added moral suffering and humiliation to the victim, especially by forcing her husband to witness the act from a distance. Considering the three aggravating circumstancesastucia (fraud/guile), despoblado (uninhabited place), and ignominiaand the absence of any extenuating circumstance, the penalty was increased. Each accused was sentenced to seventeen years, four months, and one day of reclusión temporal, to indemnify Dorotea de la Cruz jointly and severally in the amount of P500, with the accessories of the law, and to each pay one-half of the costs.