G.R. No. L-61571 November 13, 1985
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILFRANDO MANLIGAS, accused-appellant.

FACTS

On the evening of January 1, 1969, Virginia Colipano, an 18-year-old barrio girl, was tending a store in her family’s house in Bansalan, Davao del Sur. The accused-appellant, Wilfrando Manligas, a married man known to Virginia, arrived with companions. After his companions left, Manligas remained. He then drew a hunting knife, ordered Virginia upstairs, and kicked over a table, extinguishing the kerosene lamp. In the ensuing darkness, he forcibly brought her to the second floor. Despite her resistance, which included attempts to shout, Manligas covered her mouth, pushed her down, and with a knife in hand, succeeded in having carnal knowledge of her. He then threatened her not to report the incident. Her sister, Carina, arrived to find Virginia crying and Manligas pale and trembling.
Virginia reported the incident the next day. The barrio captain summoned Manligas, who admitted the sexual intercourse and requested a settlement. He then fled instead of fetching his parents as instructed. A medical examination of Virginia revealed fresh lacerations on her hymen and the presence of seminal fluid, consistent with a recent first sexual experience. Manligas was arrested over four years later. His defense was that the intercourse was consensual, claiming Virginia was his sweetheart and that they had intercourse multiple times before, including twice on the night in question.

ISSUE

Whether the trial court erred in convicting Wilfrando Manligas of rape, giving credence to the prosecution’s evidence over the defense of consensual intercourse.

RULING

The Supreme Court affirmed the conviction. The trial court’s assessment of the witnesses’ credibility is accorded great respect. Virginia’s testimony, corroborated by her immediate outcry to her sister, her emotional breakdown on the witness stand, and the medical findings of recent hymenal lacerations, firmly established lack of consent and the use of force and intimidation. The medical evidence directly contradicted Manligas’s claim of prior consensual relations, proving this was her first sexual intercourse. The circumstances—the drawn knife, the overturned lamp creating darkness, the torrential rain that prevented neighbors from hearing her, and Manligas’s immediate flight and attempt to settle the case—all corroborated the rape.
The defense arguments were unavailing. The lack of physical injuries on Virginia did not negate rape, as resistance is not required to be overpowering when the attacker is armed. Her failure to summon neighbors was reasonably explained by the heavy rain and the intimidation caused by the weapon. Manligas’s flight and his admission before the barrio captain demonstrated consciousness of guilt. His defense was correctly found by the trial court to be contradictory and incredible. Consequently, his guilt was proven beyond reasonable doubt. The Court affirmed the penalty of reclusion perpetua but increased the civil indemnity to twenty thousand pesos.