G.R. No. 122498; September 27, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ELMEDIO CAJARA, accused-appellant.

FACTS

The accused-appellant, Elmedio Cajara, was convicted by the trial court of Qualified Rape and sentenced to death for the alleged rape of his sister-in-law, Marita Cajote, on May 30, 1994, in Basey, Samar. The prosecution’s narrative, as credited by the trial court, detailed that Marita was staying in the one-room house of Cajara and his common-law wife, Meling (Marita’s sister). In the early morning, Cajara, armed with a bolo, threatened and raped Marita despite her struggles and shouts for help. The incident allegedly occurred in the presence of Meling and their two children. Marita subsequently reported the crime, overcoming initial discouragement from relatives and local officials due to Cajara’s feared reputation. A medical examination revealed a healed hymenal laceration.
In his defense, Cajara, along with Meling, denied the rape. He claimed he was asleep and was later awakened by a quarrel between the sisters, prompted by Marita placing her leg over him. They asserted the charge was fabricated.

ISSUE

The core issue for automatic review was whether the trial court correctly convicted Cajara of Qualified Rape punishable by death.

RULING

The Supreme Court affirmed the conviction for rape but modified the classification and penalty. The Court upheld the trial court’s assessment of credibility, ruling that the victim’s clear, consistent, and candid testimony, which withstood rigorous cross-examination, prevailed over the bare denials of the accused and his wife. The medical finding, while indicating a healed laceration, did not negate the commission of rape.
However, the Court found the qualifying circumstance for the imposition of the death penalty under Republic Act No. 7659 was not sufficiently proven. The law required that the rape be committed “in full view” of specified relatives. The evidence established that the rape occurred in a one-room dwelling with the wife and children present. The Court reasoned that “in full view” necessitates a sense of spectacle or intentional exhibition, meaning the relatives were consciously made to witness the act. The record did not conclusively show that Meling and the children were compelled to be actual spectators, as the wife had initially covered her head with a mosquito net. Thus, the circumstance of being “in full view” was not attendant.
Consequently, the crime was simple rape, punishable by reclusion perpetua. The Court also awarded civil indemnity and moral damages to the victim. The decision of the trial court was modified accordingly.