G.R. No. 27633, December 2, 1927
PEOPLE OF THE PHILIPPINE ISLANDS vs. JUAN DE GUZMAN, ET AL.

FACTS

In the evening of November 20, 1925, appellants Juan de Guzman, Eugenio de la Cruz, and Eduardo Mojica followed sisters Rosa Salvador (14 years old) and Casimira Salvador (15 years old) as they were returning home. At a lonely spot, Juan de Guzman and Eugenio de la Cruz seized Rosa by force and led her to a nearby forest, while Eduardo Mojica restrained Casimira, threatening her with a penknife. Casimira escaped and sought help. The three appellants succeeded in forcibly taking Rosa to the forest. There, with Eduardo Mojica holding her hands and Eugenio de la Cruz holding her feet, Juan de Guzman had carnal knowledge of Rosa against her will. Afterwards, they forcibly took her to various locations, including a house in Novaliches and a Protestant minister’s house, where an attempt was made to have her sign a marriage document. She refused and was forced to thumb-mark it. The minister, upon learning she had been abducted, tore the document. Rosa’s mother later found her at Juan de Guzman’s house. The defense claimed Rosa and Juan were sweethearts and had voluntarily married.

ISSUE

Whether the appellants are guilty of the complex crime of abduction with rape.

RULING

Yes. The Supreme Court found the appellants guilty of the complex crime of abduction with rape under Article 445 of the Penal Code. The trial court’s finding of abduction was affirmed, but the crime was properly qualified as abduction with rape, as the forcible abduction was a means to commit rape. All three appellants, acting in concert with a common purpose, are equally liable for the complex crime. The aggravating circumstances of abuse of superior strength and commission in an uninhabited place were present. For appellants Juan de Guzman and Eduardo Mojica, the penalty for the graver crime (rape) in its maximum degreereclusion temporalwas imposed at its maximum duration of 20 years, due to the aggravating circumstances. For appellant Eugenio de la Cruz, who was under 18 years old, the penalty was reduced by one degree to prision mayor, also imposed at its maximum of 12 years. The appellants were also ordered to jointly and severally indemnify Rosa Salvador in the sum of P500, and Juan de Guzman was ordered to acknowledge and support any offspring. The appealed judgment was modified accordingly.