G.R. No. 186417; July 27, 2011
People of the Philippines, Plaintiff-Appellee, vs. Felipe Mirandilla, Jr., Defendant-Appellant.

FACTS

The case involves the 39-day ordeal of AAA. On December 2, 2000, during a fiesta in Legazpi City, AAA was abducted from a plaza by Felipe Mirandilla, Jr., and his companions, who used a knife and a gun to threaten her. She was forced to walk for hours, then taken via tricycle to the Gallera de Legazpi in Rawis. There, Mirandilla, at gunpoint, ordered her to remove her pants, and when she resisted, he slapped her, hit her with a gun, inserted three fingers into her vagina, and then raped her. Over the following days, Mirandilla repeatedly detained and moved AAA to various locations (including Bogtong, a nipa hut, Guinobatan, Bonga, and Camalig), raping her multiple times, including one instance of oral rape. AAA testified to being raped approximately 27 times. On January 11, 2001, she managed to escape, was aided by Evelyn Guevarra, and reported to the police, where she identified Mirandilla from photographs. A medical examination by Dr. Sarah Vasquez confirmed hymenal lacerations consistent with sexual intercourse and that AAA had contracted gonorrhea. Mirandilla denied the charges, claiming AAA was his live-in partner, that they met in October 2000, became lovers, eloped, and lived together consensually, engaging in regular sexual relations. He alleged that AAA left him after a quarrel following an abortion. The Regional Trial Court (RTC) convicted Mirandilla of kidnapping, four counts of rape, and one count of rape through sexual assault. The Court of Appeals (CA) affirmed with modification, finding him guilty of the special complex crime of kidnapping with rape, four counts of rape, and one count of rape by sexual assault.

ISSUE

Whether the Court of Appeals erred in finding Felipe Mirandilla, Jr. guilty beyond reasonable doubt of the special complex crime of kidnapping with rape, multiple counts of rape, and rape through sexual assault, despite his defense that he and the victim were live-in partners and that their sexual relations were consensual.

RULING

The Supreme Court modified the CA decision and found Felipe Mirandilla, Jr. guilty of the special complex crime of kidnapping and illegal detention with rape. The Court rejected Mirandilla’s defense of a consensual live-in relationship, noting his failure to present credible evidence or witnesses to substantiate his claim. In contrast, AAA’s detailed, consistent, and credible testimony about her abduction, detention, and repeated rapes, corroborated by medical findings, established Mirandilla’s guilt beyond reasonable doubt. The Court found that the elements of kidnapping and illegal detention with rape were present: AAA was deprived of her liberty for 39 days, and the rape was committed during her captivity. The defense of a romantic relationship was deemed a mere fabrication to evade liability.