G.R. No. 200080 ; September 18, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. MARVIN CAYANAN, Accused-Appellant.

FACTS

The accused-appellant, Marvin Cayanan, was convicted by the Regional Trial Court of two crimes: Qualified Rape and Forcible Abduction with Qualified Rape. The charges stemmed from two incidents involving his 15-year-old sister-in-law, AAA. On February 1, 2001, Cayanan entered AAA’s house while she was alone and asleep, caressed and kissed her, forcibly removed her shorts, and raped her while threatening her with a knife. On February 26, 2001, Cayanan forcibly abducted AAA from her school gate, brought her to various locations, and eventually raped her at his sister’s house. The victim’s testimony was corroborated by her friend and mother, and a psychiatrist testified to her depressive symptoms consistent with sexual abuse. Cayanan raised the sweetheart defense, presenting alleged love letters, which the trial court found unauthenticated.
The Court of Appeals affirmed the convictions but modified the awarded damages. Cayanan appealed to the Supreme Court, seeking a review of the CA decision.

ISSUE

The primary issues were: (1) whether the CA erred in affirming Cayanan’s convictions, and (2) whether the crime of Forcible Abduction with Qualified Rape was properly appreciated.

RULING

The Supreme Court affirmed the convictions with modification. The Court upheld the factual findings of the lower courts, ruling that the prosecution successfully established Cayanan’s guilt beyond reasonable doubt. The victim’s credible and consistent testimony, corroborated by other witnesses, prevailed over the weak sweetheart defense. For such a defense to be credible, it must be supported by independent proof like tokens or photographs, not just unauthenticated letters and testimonial evidence.
On the second issue, the Court applied the doctrine of absorption. It ruled that Cayanan should be convicted only of Qualified Rape for the February 26 incident, as the forcible abduction was absorbed by the rape. The circumstances clearly showed that the abduction’s sole purpose was to commit rape, making the abduction a mere means to that end. Thus, the separate conviction for forcible abduction was set aside.
Finally, the Court affirmed the CA’s awards of civil indemnity, moral damages, and exemplary damages in accordance with prevailing jurisprudence, and imposed legal interest on all damages until fully paid. The dispositive portion modified the CA decision by finding Cayanan guilty only of Qualified Rape in Criminal Case No. 1498-M-2001, but affirmed all other aspects.