G.R. No. L-53569 February 23, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. FELIPE ROBLES, accused-appellant.

FACTS

The accused-appellant, Felipe Robles, was the common-law husband of Ocita Nunez and lived with her and her 12-year-old daughter, Arlene Macadat, in Masbate. Arlene regarded Robles as a father figure. On the evening of May 27, 1979, Robles brought Arlene to a remote copra drier. There, he held her hands, forced her to lie down, covered her mouth when she tried to shout, removed her panty, and succeeded in having sexual intercourse with her. He threatened to kill her if she reported the incident. Two days later, on May 29, Robles again sexually assaulted Arlene twice near a riverbank, poking an arrow at her to prevent her from shouting. Arlene eventually reported the rapes to her mother, leading to a complaint and Robles’s prosecution for rape under an information charging one count of carnal knowledge through force and intimidation.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Felipe Robles committed rape against Arlene Macadat through the use of force or intimidation, thereby rendering her submission involuntary.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of the 12-year-old complainant credible and consistent. It rejected the defense of alleged courtship and consent, noting it was inconceivable that a young girl would publicly disclose a rape, undergo medical examination, and endure a trial if her motive was not to seek justice for a grievous wrong. The Court emphasized that in cases involving a stepfather and a minor, actual physical force need not be extensively proven. The moral ascendancy and influence wielded by Robles, as a parental figure upon whom Arlene was dependent, coupled with his threats of bodily harm, constituted sufficient intimidation to vitiate consent and bring the act within the definition of rape. The claim that the charge arose merely because Robles was caught kissing Arlene was deemed flimsy and incredible, given the mother’s dependent relationship with him and her unlikely consent to file a serious charge without belief in his guilt. While the evidence indicated three acts, the conviction was properly for the single offense charged in the information. The penalty of reclusion perpetua was affirmed, with the modification that Robles must pay Arlene P20,000.00 as civil indemnity.