G.R. Nos. L-62281-82 July 16, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARMELO FELIX Y RANADA, FELIX POBLETE Y LUMBOY, and ARTEMIO FELIX Y ELPEDES, accused-appellants.

FACTS

On the evening of October 14, 1977, Marlene Donato visited a friend’s house where appellants were present. Upon leaving, she waited for transportation. The three appellants approached; Carmelo Felix forcibly held her, covering her mouth, while Felix Poblete hailed a tricycle. They forced her inside and proceeded to Bunton bridge. There, they pulled her under the bridge. Carmelo Felix rendered her unconscious with a blow to the stomach and raped her. Upon regaining consciousness, she saw Artemio Felix also raping her, while Felix Poblete acted as a lookout above. Hearing a gunshot, the two fled, leaving Marlene in the water. Responding policemen found her, and she immediately identified her assailants. A medical examination revealed an incomplete hymenal laceration and erythema in the labia minora, though no sperm cells were found.
The defense claimed Carmelo and Marlene were former sweethearts who had consensual relations, and that the incident was fabricated after their relationship ended. They argued the absence of external injuries and spermatozoa negated rape. The trial court convicted Carmelo and Artemio Felix as principals of rape and sentenced them to reclusion perpetua. Felix Poblete, a minor, was convicted as an accomplice. All were ordered to pay damages.

ISSUE

Whether the prosecution proved beyond reasonable doubt the crime of rape through force and intimidation against the appellants.

RULING

Yes, the conviction is affirmed. The Court found the testimony of the victim credible and consistent. The defense of a prior romantic relationship was unsubstantiated and could not overcome the clear narrative of abduction and violence. The legal logic establishes that the essential elements of carnal knowledge through force were sufficiently proven. The absence of external bodily injuries is not fatal, as the blow to her stomach, which caused unconsciousness, may not leave visible marks. The medical findings, specifically the hymenal laceration and erythema, corroborated the fact of recent sexual intercourse and physical trauma. The lack of spermatozoa does not disprove rape, as the slightest penetration consummates the crime, and the evidence could have been washed away when she was forced into the water. The flight of the appellants upon hearing the gunshot indicated consciousness of guilt. The positive identification by the victim, both at the scene and later at the hospital, provided strong evidence of their participation. The award of damages was modified to moral damages and civil indemnity, deleting exemplary damages for lack of aggravating circumstances. The decision of the trial court was affirmed with modifications.