G.R. No. 137759; September 3, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARCHIBALD PATOSA Y LASTIMADO, accused-appellant.
FACTS
The accused-appellant, Archibald Patosa, is a relative of the victim, Chanil Escosais, a 16-year-old minor whom he and his wife treated as their own daughter and supported through school. On April 28, 1996, in Bacoor, Cavite, while the accused’s wife was away, he entered Chanil’s room late at night. Despite her pleas (“Tiong, huwag po”) and struggles, he punched her, forcibly undressed her, kissed and bit her various body parts, and threatened to kill her (“putang ina mo, papatayin kita”) if she made noise. He then had carnal knowledge of her against her will. The next day, Chanil confided in her cousin and later reported the rape to the police and the NBI. A medico-legal examination confirmed healing hymenal lacerations consistent with the alleged date of the rape. The accused claimed the sexual intercourse was consensual, alleging prior amorous relations. The Regional Trial Court convicted him of rape and sentenced him to reclusion perpetua.
ISSUE
Whether the accused-appellant is guilty beyond reasonable doubt of the crime of rape.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimony of the victim to be credible, natural, convincing, and consistent with human nature and the normal course of things. Her detailed account of the force, intimidation, and violence employed by the accused, coupled with her immediate report of the incident, established the elements of rape. The accused’s claim of consensual sex was rejected as a mere denial, which cannot prevail over the positive and categorical testimony of the victim. The medico-legal findings corroborated her claim. The Court also held that the accused could not be convicted of the lesser crime of qualified seduction, as he was definitively charged with rape in the information, which alleged carnal knowledge through force and intimidation, not all elements of qualified seduction. The penalty of reclusion perpetua was affirmed. The accused was ordered to pay the victim P50,000.00 as civil indemnity and P50,000.00 as moral damages.
