G.R. No. L-31227 May 31, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO SAVELLANO, defendant-appellant.

FACTS

The prosecution evidence established that on July 18, 1969, seventeen-year-old Zosima Jenilla, a petite girl with poor hearing and limited schooling, was sent on an errand. While walking, she was seized from behind by Antonio Savellano, a taller and stronger farmer she knew. He dragged her to a cornfield, covered her mouth to stifle her shouts, and pinned her down despite her vigorous resistance, which included kicking, slapping, and scratching his face. Savellano, using his left hand and the stump of his right arm, succeeded in having carnal knowledge with her. Afterward, he threatened to kill her if she told anyone. Zosima immediately reported the rape to her sister and brother-in-law, her dress soiled with mud. The incident was reported to authorities, leading to Savellano’s arrest that same afternoon.
The defense presented a contradictory narrative, claiming that Zosima and Savellano were sweethearts who had engaged in consensual sexual intercourse on multiple prior occasions. Savellano alleged that on the day in question, they had agreed to meet and had sexual intercourse by mutual consent. To bolster this claim, the defense presented witnesses, including Savellano’s mother, who testified to a supposed courtship and even a prior marriage proposal from Savellano’s parents to Zosima’s parents.

ISSUE

The core issue is whether the sexual intercourse between Antonio Savellano and Zosima Jenilla was rape committed by force and intimidation or a consensual act between sweethearts.

RULING

The Supreme Court affirmed the conviction for rape. The Court found the prosecution’s version credible and the defense of a sweetheart relationship utterly implausible. The trial court meticulously dismantled the defense’s story, noting several irreconcilable points. First, if they were indeed sweethearts who had prior intimate relations, it was unnatural that no such encounters occurred in the over five months preceding the incident. Second, Zosima’s immediate and distressed report of the assault, her soiled clothing, and her consistent, tearful testimony in court were completely inconsistent with the behavior of a consenting lover. Third, the Court took judicial notice of rural Filipino courtship customs, which involve formal parental visits and proposals; no such formalities occurred here, undermining the claim of a serious relationship headed for marriage.
The Court emphasized that Zosima’s credible testimony of resistance, corroborated by the scratches found on Savellano’s face and her immediate complaint, sufficiently proved the element of force. Her physical handicap and small stature against Savellano’s superior strength made her resistance futile but did not negate its existence. The medical findings, while indicating she was no longer a virgin, were consistent with a recent sexual act and did not contradict her narrative. The defense of consensual sex, built on uncorroborated and contrived testimony, was rightly rejected by the trial court. Thus, the judgment convicting Antonio Savellano of rape and sentencing him to reclusion perpetua was upheld.