G.R. No. 134139 -40 February 15, 2002
People of the Philippines, plaintiff-appellee, vs. Wilfredo Somodio, accused-appellant.

FACTS

Accused-appellant Wilfredo Somodio was charged with two counts of rape against Maylene Co. The first incident allegedly occurred in March 1995, when Maylene was 11 years old. The prosecution’s narrative states that Somodio, a neighbor, lured Maylene to his house under a pretext, dragged her inside, and had carnal knowledge of her. A week later, he again summoned her and threatened her to keep silent. Maylene eventually revealed the assault to her mother, Aurora, leading to a medical examination that showed healed lacerations. The complaint, however, was not immediately filed.
The second charge pertained to alleged incidents in 1997, when Maylene was 14. The prosecution claimed Somodio reappeared and, by threatening to reveal the 1995 incident, forced her to have sexual intercourse on multiple occasions. The matter came to light when Maylene’s aunt saw her leaving Somodio’s house. Somodio denied all accusations, claiming Maylene had a crush on him and voluntarily entered his room in 1997, where she initiated intimate contact. He also presented a document, which Maylene had signed at his lawyer’s office, purportedly to support his defense.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt the guilt of the accused for the crimes of rape, particularly statutory rape for the 1995 incident and forcible rape for the 1997 incidents.

RULING

The Supreme Court affirmed the conviction for statutory rape in Criminal Case No. 98-286 but acquitted the accused in Criminal Case No. 98-287. For the 1995 incident, the Court upheld the statutory rape conviction. The victim’s birth certificate, admitted by the defense, conclusively established she was 11 years old at the time. Under Article 335 of the Revised Penal Code, carnal knowledge of a girl under twelve constitutes rape, irrespective of consent or the use of force. The victim’s credible testimony, corroborated by her immediate outcry to her mother and the medical findings of healed lacerations, sufficiently proved the sexual act. The defense’s claim of a prior romantic relationship was immaterial to statutory rape.
For the 1997 incidents, the Court found reasonable doubt warranting acquittal. The prosecution failed to prove force, threat, or intimidation beyond reasonable doubt. The victim’s claim that she submitted due to Somodio’s threat to expose the past rape was deemed insufficient. Her continued compliance over multiple occasions, without any attempt to seek help despite opportunities, and her act of signing a document for the accused’s lawyer, eroded the credibility of her claim of ongoing coercion. The element of voluntariness in her actions created doubt that the sexual acts were against her will. Thus, the acquittal for the 1997 charge was affirmed.