G.R. No. 210430 , February 18, 2015
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RONALD NICAL y ALMINARIO, Accused-Appellant.

FACTS

The accused-appellant, Ronald Nical y Alminario, was charged with rape in an Information dated August 28, 2007, alleging that on or about August 23, 2007, in Dasmariñas, Cavite, he had carnal knowledge of the victim, AAA, through force, violence, and intimidation, against her will. AAA, a maid, testified that while folding laundry in a room, the accused-appellant entered, embraced her, and when she tried to flee, he grabbed her shorts, pushed her against a wall causing her head to hit it, making her dizzy. She escaped briefly but was caught in the sala, where she lost consciousness after being embraced again. Upon regaining consciousness, she found herself naked in the room with the accused-appellant on top of her, inserting his penis into her vagina, causing pain. She pushed him off with her knee and reported the incident. A medical examination by Dr. Angelito Magno revealed no signs of recent physical injuries, sexual abuse, or lacerations, and noted that AAA’s hymen was no longer intact, though he stated this did not preclude the possibility of rape days earlier. The accused-appellant denied the rape, claiming AAA sat on his stomach while he was resting, and he pushed her away, causing her to fall and lose consciousness; he revived her, and alleged the charge was motivated by AAA’s jealousy over another maid he was courting. The Regional Trial Court (RTC) convicted him of rape, sentencing him to reclusion perpetua and ordering him to pay civil indemnity, moral damages, and exemplary damages. The Court of Appeals (CA) affirmed the conviction but increased the exemplary damages and added interest.

ISSUE

Whether the accused-appellant’s guilt for the crime of rape was proven beyond reasonable doubt, considering the medical findings and the allegation of unconsciousness not stated in the Information.

RULING

The Supreme Court affirmed the conviction. The Court held that the medical findings, which showed no physical injuries or fresh lacerations, do not negate rape, as medical evidence is not indispensable to prove rape; the essential element is carnal knowledge, which does not require proof of vaginal penetration or hymenal rupture. AAA’s testimony was clear, credible, and consistent, detailing the use of force and violence leading to her unconsciousness and sexual assault. The Court rejected the accused-appellant’s defense, noting it was improbable and failed to cast doubt on AAA’s account. Regarding the argument on unconsciousness not being alleged in the Information, the Court ruled that the Information sufficiently charged rape through force, violence, and intimidation, and AAA’s unconsciousness was a result of the accused-appellant’s forceful actions, not a separate mode of committing rape. Thus, the penalty of reclusion perpetua was upheld, and the awards of civil indemnity, moral damages, and exemplary damages, with interest, were affirmed.