GR L 37712; (November, 1982) (Digest)
G.R. No. L-37712 November 19, 1982
The People of the Philippines, plaintiff-appellee, vs. Ernesto Syquioco, defendant-appellant.
FACTS
The accused, Ernesto Syquioco, was convicted of forcible abduction with rape against Andrea Balce, a 19-year-old student. On October 11, 1971, Balce, feeling ill, boarded a tricycle to go to a clinic. Syquioco was already inside. He ordered the driver to Labangan instead, dragged Balce into a warehouse, and forced her onto a bed. He compelled her to drink water, after which she fell asleep. She awoke the next morning with vaginal pain and bleeding. Syquioco threatened to kill her if she spoke.
When her mother arrived the next day, Balce immediately embraced her and declared, “I did not like it. It is not my voluntary will,” before fainting. A medical certificate later confirmed a hymenal laceration. The defense denied the accusation, claiming the relationship was consensual.
ISSUE
The core issue is the credibility of the complainant’s testimony versus the accused’s denial, specifically whether the prosecution proved the crime of forcible abduction with rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The legal logic centered on the credibility of the victim’s consistent and corroborated testimony. Her spontaneous declaration to her mother upon rescue—”I did not like it. It is not my voluntary will”—was a crucial part of the res gestae, possessing strong probative value as a natural outburst made to the most logical confidante. Her subsequent distress in court and the medical evidence of physical injury substantiated her account.
The Court found the defense of consensuality implausible, noting the accused’s use of force, threats, and the administration of a substance that caused unconsciousness. His flight and evasion of arrest for over a year further undermined his credibility. Consequently, his guilt was proven beyond reasonable doubt. The penalty of reclusion perpetua was sustained, but the indemnity to the victim was increased from P5,000 to P12,000.