G.R. No. 133185 ; February 6, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDWARD OLLAMINA, accused-appellant.

FACTS

Private complainant Julie Ann Redulla, then fifteen years old, accused her neighbor, Edward Ollamina, of rape. She testified that on the evening of January 21, 1997, Ollamina invited her to a birthday party in Sasa, Davao City. She agreed and went with him without seeking permission from her aunt. Upon arrival at a dark, unlit house in a squatter area, Ollamina brought her inside, threatened to kill her if she shouted, forced her to lie down, and had carnal knowledge with her against her will. The following day, she reported the incident and underwent a medical examination, which revealed an intact but distensible hymen and a positive semenology result.
The accused-appellant, Edward Ollamina, denied the accusation and presented a different version. He claimed that he and Julie Ann were sweethearts and that on the said evening, she was crying because her aunt discovered their relationship and wanted her to leave. She allegedly begged him to elope. They went to a house in Sasa to rent a room but, after talking, realized they were not ready for a commitment and returned home that same night. He denied having sexual intercourse with her.

ISSUE

Whether the guilt of the accused-appellant for the crime of rape through force or intimidation was proven beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED Edward Ollamina. The Court emphasized that in rape cases, the prosecution’s evidence must stand on its own merits, and the testimony of the complainant must be scrutinized with extreme caution. For rape through force or intimidation under Article 335 of the Revised Penal Code, the prosecution must conclusively prove that such force or intimidation was employed to achieve carnal knowledge.
The Court found Julie Ann’s testimony and behavior inconsistent with that of an unwilling victim. She voluntarily accompanied the accused, a virtual stranger, late at night without seeking permission. She entered a dark, unfamiliar house without protest. During the alleged assault, she did not shout or make any attempt to escape, despite opportunities to do so, such as during the jeepney ride or upon seeing the dark, deserted house. Her passive demeanor and failure to offer any physical resistance, coupled with the lack of extragenital injuries, negated the presence of force or intimidation. The Court ruled that her actions were more indicative of consent than of a violation committed against her will. Consequently, the prosecution failed to prove the essential element of force or intimidation beyond reasonable doubt, warranting acquittal.