GR L 38449; (November, 1982) (Digest)
G.R. No. L-38449 November 25, 1982
People of the Philippines, plaintiff-appellee, vs. Dominador Manzano, defendant-appellant.
FACTS
The accused-appellant, Dominador Manzano, was convicted of rape by the Court of First Instance of Pangasinan. The prosecution evidence established that on November 28, 1968, the complainant, Jovita Nacional, was sent on an errand. Upon her return, Manzano followed, forcibly carried her to an underbrush, and, despite her struggles and after threatening to kill her if she shouted, succeeded in having carnal knowledge with her. She immediately reported the assault to her parents, and her torn and bloodied panty was presented as evidence.
The trial court found Manzano guilty and imposed an indeterminate penalty. However, as the prescribed penalty for rape is reclusion perpetua, the Court of Appeals certified the case to the Supreme Court because the Indeterminate Sentence Law does not apply to offenses punishable by life imprisonment, and the Supreme Court has exclusive appellate jurisdiction over such cases.
ISSUE
Whether the trial court erred in convicting the accused-appellant of the crime of rape.
RULING
The Supreme Court affirmed the conviction but modified the penalty. The Court found the testimony of the complainant to be credible, straightforward, and consistent, thereby proving the essential elements of rape—carnal knowledge through force and intimidation. Her immediate reporting of the incident to her parents and the physical evidence (the torn, bloodied panty) corroborated her account. The defense of alibi was rejected for being weak and unsubstantiated.
The Court also affirmed the presence of the aggravating circumstance of an uninhabited place, as the crime was committed in an underbrush approximately 40 meters from the road, with the nearest house being 200 meters away, a location purposely sought to avoid detection. Consequently, the award of moral and exemplary damages was upheld as legally justified. However, the penalty was corrected. Since the crime of rape under Article 335 of the Revised Penal Code is punishable by reclusion perpetua, the Indeterminate Sentence Law is inapplicable. The trial court’s indeterminate sentence was set aside, and the accused-appellant was properly sentenced to suffer the penalty of reclusion perpetua.