G.R. No. 30715 / July 27, 1929
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. ELPIDIO CORCINO, defendant-appellant.

FACTS

On the night of June 18, 1928, in Alcala, Cagayan, the offended party, Maria Tejano (a 19-year-old married woman), was asleep in her house with her young daughter and two young companions. Her husband was away fishing. The defendant, Elpidio Corcino, who had visited earlier that evening, later returned, secretly entered the house through a window (cutting its securing string), and, while the occupants were asleep and the light had gone out, had carnal knowledge of Maria Tejano without her consent. She initially thought the man was her husband but realized he was not when he answered her call in a low voice. She resisted, called for help, and prevented Corcino from escaping through the window. When apprehended, Corcino begged for pardon and admitted his guilt to the barrio lieutenant, who reduced his confession to writing (Exhibit A). Corcino later claimed his confession was coerced and alleged a prior illicit relationship with Tejano, which she denied.

ISSUE

Whether the trial court erred in convicting the defendant of rape based on the evidence presented, particularly regarding: (1) the validity of his confession; (2) the credibility of the offended party’s account; and (3) the sufficiency of proof beyond reasonable doubt.

RULING

The Supreme Court AFFIRMED the conviction. The evidence established beyond reasonable doubt that the defendant committed rape. The confession (Exhibit A) was voluntary and corroborated by witness testimony and physical evidence (e.g., the cut window string, Corcino’s lowered drawers during escape). The offended party’s testimony was credible and consistenther initial belief that the assailant was her husband explained why she did not immediately resist. The defense of a prior consensual relationship was implausible, as Tejano would not have called for help if that were true. The crime was aggravated by nighttime, dwelling place, and unlawful entry, warranting the imposition of the maximum penalty of reclusion temporal (17 years, 4 months, and 1 day).