GR 97425; (September, 1996) (Digest)
G.R. No. 97425 September 24, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMUALDO MIRANDA y GERONIMO @ WALDO and ORLANDO PAJARILIAGA, (at large), accused-appellant.
FACTS
On August 25, 1989, 13-year-old Maribel Mendiola was accosted by appellant Romualdo Miranda and his co-accused Orlando Pajarillaga while walking home from school in Hagonoy, Bulacan. Armed with a knife, they forced her into a jeep and brought her to a nipa hut. There, she was given a drugged soft drink, causing her to fall into a dream-like state. In this condition, she saw appellant on top of her, performing sexual intercourse, while Pajarillaga watched. Upon waking the next morning, she felt pain, had difficulty urinating, and noticed bleeding and injection marks on her arm. The accused then brought her to her grandmother’s house with instructions not to report the incident. She later confided in her parents, who had her medically examined. The examination revealed healed hymenal lacerations and the presence of spermatozoa.
ISSUE
Whether the prosecution proved beyond reasonable doubt the crime of rape through force, intimidation, and the use of drugs.
RULING
Yes. The Supreme Court affirmed the conviction but modified the penalty and damages. The Court found the testimony of the young victim to be credible, consistent, and sincere. It ruled that force and intimidation were sufficiently established by the initial threat of a knife and the subsequent administration of drugs, which rendered the victim physically incapable of resistance. The defense of alibi was correctly rejected by the trial court as inherently weak and unsubstantiated. The Court emphasized that the victim’s failure to escape during the journey or immediately after the assault did not imply consent, as the fear instilled by the accused and the effects of the drugs negated any meaningful opportunity for resistance. The penalty was corrected from life imprisonment to reclusion perpetua, as the latter is the precise penalty prescribed by the Revised Penal Code. Moral damages were increased from P20,000.00 to P50,000.00 due to the particularly despicable nature of the crime committed against a minor.