GR 175946; (March, 2007) (Digest)
G.R. No. 175946, March 23, 2007
People of the Philippines vs. Raymundo Dadulla @ “Mundo”
FACTS
The appellant, Raymundo Dadulla, was charged with the rape of AAA, his sister-in-law, on May 22, 1995. The prosecution’s evidence established that appellant deceived AAA by asking her to treat his sick common-law wife at his house. Upon arrival, he led her to a room, locked the door, and threatened her with a bolo, stating he would kill her. AAA, feeling chest pains and fear, fainted. She regained consciousness to find appellant on top of her, copulating with her, with her shorts and panty removed. She immediately reported the incident to the barangay chairman. During a confrontation, appellant admitted to the rape in writing and also wrote a note asking for forgiveness. A medical examination later confirmed injuries consistent with sexual assault.
The defense presented a starkly different version. Appellant claimed he and AAA were secret lovers and that the charge was fabricated after he tried to end their affair. He alleged he was coerced by armed men into signing the admission at the barangay hall. He denied the rape occurred, stating AAA visited him that day and left after an argument about their relationship.
ISSUE
The core issue is whether the prosecution proved the guilt of the appellant for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the appellant’s conviction for simple rape. The Court upheld the factual findings of the lower courts, giving great weight to the trial court’s assessment of witness credibility, which found the testimony of the victim, AAA, to be clear, consistent, and credible. Her immediate report of the incident, the medical findings, and the appellant’s own written admissions during the barangay confrontation constituted a strong and coherent narrative of guilt.
The Court rejected the appellant’s defenses of a fabricated charge and coercion. His claim of a romantic affair was uncorroborated and deemed a common and unsubstantiated ploy to evade liability. His allegation of being forced to sign the admission was not credible, as he failed to report any coercion to authorities promptly or seek protection. The written admissions, being voluntary, carried significant weight against him. The elements of rape—carnal knowledge through force or intimidation—were sufficiently established by AAA’s testimony, which detailed the threats and her subsequent unconsciousness, rendering her incapable of giving consent. The Court modified the damages awarded, deleting exemplary damages for lack of aggravating circumstances but affirming civil indemnity and moral damages.
