G.R. No. L-49910 November 28, 1980
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LORETO AQUIAPAS Y GUAY alias “Ablao” alias “Soriano Aquiapas,” defendant-appellant.

FACTS

The prosecution established that on the evening of September 19, 1978, complainant Emiliana Boas was walking home along a road in Sison, Pangasinan, during a heavy downpour. Appellant Loreto Aquiapas, intoxicated, emerged, grabbed her, and repeatedly assaulted her. He boxed her face, causing her nose to bleed, strangled her until she lost consciousness, and ripped off her clothing. Upon regaining consciousness, she found herself naked with appellant on top of her, felt pain in her private parts, and managed to crawl to a nearby house to shout for help. She was rescued by Esteban Lateral, given clothing, and later hospitalized. Medical examination revealed injuries on her face, neck, thighs, and vaginal area consistent with forcible intercourse.
The appellant admitted to sexual intercourse but claimed it was consensual, alleging a pre-existing amorous relationship with the complainant. He argued that the meeting was pre-arranged, that she did not shout during the act, and that her nakedness and the prosecution’s failure to present her torn garments indicated consent rather than rape.

ISSUE

Whether the sexual intercourse between the appellant and the complainant was consensual, thereby negating the crime of rape.

RULING

The Supreme Court affirmed the conviction for rape and the penalty of reclusion perpetua. The Court found the appellant’s claim of consent to be a “complete prevarication” and devoid of merit. The legal logic centered on the irreconcilable conflict between the appellant’s narrative and the objective evidence of force. The medical certificate, detailing the complainant’s multiple abrasions, contusions, and vaginal tenderness, provided conclusive physical evidence of violent resistance, directly negating any possibility of voluntary submission. The Court emphasized that such injuries “stamp the latter’s testimony… with the impress of solid truth.”
Furthermore, the appellant’s own post-incident sworn statement, wherein he claimed drunkenness and unawareness of his actions, contradicted his later judicial testimony of a consensual rendezvous. The Court found the complainant’s conduct—shouting for help immediately after the incident, her distressed state when found naked, and her consistent narration to rescuers and authorities—to be natural and spontaneous, indicative of a genuine victim. In contrast, the appellant’s belated story of an affair was deemed an unnatural and incredible last-ditch defense, rightly disbelieved by the trial court which observed his demeanor. The non-presentation of the torn clothing was considered an inconsequential oversight, as the totality of the evidence, particularly the medical findings and credible testimony, firmly established the element of force and violence beyond reasonable doubt.