GR 102723; (June, 1997) (Digest)
G.R. No. 102723 -24 June 19, 1997
People of the Philippines, plaintiff-appellee, vs. Eduardo Caballes and Reynaldo Mabini, accused, Eduardo Caballes, appellant.
FACTS
Accused Eduardo Caballes and Reynaldo Mabini were charged with two counts of rape committed in concert against Miguela Baculi on the evening of September 26, 1987, in Cebu City. The complaints alleged that the accused, conniving and mutually helping each other, took turns having sexual intercourse with the complainant by use of force, violence, and intimidation, with Mabini pointing a knife at her. The victim, a married woman, testified that while on her way home, she was accosted by the two accused, who were her neighbors. Mabini covered her mouth and pointed a knife, while Caballes held her hands. They dragged her to a secluded area where, despite her attempts to escape, she was slapped, punched, and strangled. Caballes first raped her while Mabini held her hands and pointed the knife. Afterwards, they exchanged positions and Mabini also raped her. The victim reported the incident to relatives, leading to the arrest of the accused that same night. A medical examination revealed injuries consistent with force and trauma to her genitalia. Both accused admitted to having sexual intercourse with the victim that night but presented contradicting defenses. Caballes claimed the act was consensual, while Mabini admitted to the rape. The Regional Trial Court convicted both accused of two counts of rape. Caballes was sentenced to two penalties of reclusion perpetua, while Mabini, due to his minority, received a lesser penalty. The court also awarded moral and exemplary damages. Caballes appealed the decision.
ISSUE
The main issue is whether the trial court erred in convicting appellant Eduardo Caballes of two counts of rape based on the evidence presented.
RULING
The Supreme Court affirmed the conviction. It held that the trial court correctly gave credence to the victim’s testimony, which was clear, convincing, and consistent. The Court emphasized that no Filipino woman would willingly expose herself to public ridicule by fabricating a story of rape. The medical findings corroborated her account of force and violence. The claim of consensual sex was rejected as contrary to human nature and the victim’s character as a decent, married woman. The Court found that the accused conspired in the commission of the crime, making each liable for the acts of the other. Consequently, two counts of rape were properly proven. The Court modified the award of damages, clarifying jurisprudence on civil indemnity, moral damages, and exemplary damages. It ruled that civil indemnity in the amount of P50,000.00 for each count of rape is automatically granted without need of further proof. Moral damages can be awarded upon sufficient proof, and exemplary damages if aggravating circumstances are present. The Court increased the damages, ordering appellant to pay, jointly and severally with Mabini, the P50,000.00 moral damages awarded by the trial court, plus an additional P25,000.00 as moral damages for each count (total P50,000.00), and civil indemnity of P50,000.00 for each count (total P100,000.00). The penalties imposed by the trial court were affirmed.
