GR L 78492; (May, 1987) (Digest)
G.R. No. L-78492 May 29, 1987
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DICK OCAPAN, accused-appellant.
FACTS
The accused-appellant, Dick Ocapan, and his common-law wife, Joselyn Ocapan, were charged with the complex crime of rape with serious illegal detention. The case against Joselyn was dismissed. The prosecution’s evidence established that the victim, Arlene Yupo, was their house helper. On January 17, 1985, after being made to drink alcohol, Arlene was allegedly raped by Dick Ocapan, who threatened her with a knife. The following day, after she informed Joselyn, she was slapped, locked in a room, and detained for five days to prevent her from reporting the incident. She was released on January 23, 1985, and later reported the crime. The defense presented a contrary version, claiming Arlene and the appellant were lovers and that she was not detained, citing witness testimony that she was seen outside the house during the alleged detention period. The trial court convicted Dick Ocapan of serious illegal detention but dismissed the rape charge due to the absence of a complaint filed by the offended party, as required for crimes against chastity.
ISSUE
The primary issue is whether the Court of Appeals correctly affirmed the conviction of Dick Ocapan for the crime of serious illegal detention and imposed the penalty of reclusion perpetua.
RULING
The Supreme Court affirmed the decision of the Court of Appeals. On the rape charge, the dismissal was correct because the filing of a complaint by the offended party is a jurisdictional requirement for crimes against chastity under Article 344 of the Revised Penal Code, and no such complaint was filed. Regarding serious illegal detention, the Court found the prosecution’s evidence credible and sufficient to prove guilt beyond reasonable doubt. The victim’s detailed testimony on her forcible restraint, supported by the circumstances of being locked in a room and guarded, established the crime. The defense of a romantic relationship was deemed insufficient to overturn the factual findings of the lower courts. The penalty was properly modified. As the victim was a minor female, the prescribed penalty under Article 267(4) of the Revised Penal Code is reclusion perpetua to death. With no modifying circumstances, the lesser penalty of reclusion perpetua was correctly imposed. The Indeterminate Sentence Law does not apply to this offense. Consequently, the petition for bail was denied. The Supreme Court adopted the appellate court’s findings and affirmed the sentence of reclusion perpetua.