People v. Dejucos
REITERATIONFacts
The Antecedents: On January 11, 1985, Eleanor Dejucos was convicted of rape by the Regional Trial Court of Masbate for the crime committed against his mother-in-law, Elena Rejuso. The prosecution presented evidence that on November 15, 1983, while Elena Rejuso was resting in her bedroom, appellant Eleanor Dejucos entered, naked from the waist down, armed with a bolo. He forcibly held the victim, who struggled and shouted for help. During the struggle, the victim fell, and the appellant pinned her down, hit her, and forcibly had sexual intercourse with her. The victim bit off part of his lip when he tried to kiss her. The appellant then placed the bolo against her neck to stop her struggles. Her shouts were heard by Uldarico Bajar, who went to the house and saw the appellant jump out of the window, naked from the waist down, and flee towards a cassava plantation. The victim, sustaining bruises and contusions, ran to Bajar for help and subsequently fainted. Bajar informed the victim's husband and the authorities. The appellant fled and was arrested six months later. Procedural History: The Regional Trial Court of Masbate convicted Eleanor Dejucos of rape and sentenced him to death, to pay P20,000.00 as moral damages, and to pay costs. The case was elevated to the Supreme Court for automatic review. The Petition: The accused-appellant's counsel de oficio prayed for the overturning of the verdict, arguing that the conviction was based on conjectures and unfounded conclusions not borne by evidence sufficient to prove guilt beyond reasonable doubt. The appellant claimed the victim consented to the sexual intercourse, alleging she was his former mistress.
Issue(s)
Whether the conviction for rape is based on sufficient evidence proving guilt beyond reasonable doubt, and whether the victim's testimony is credible and sufficiently corroborated. Whether the appellant's defense of consent is tenable, considering the appellant's version of events. Whether the appellant's flight is indicative of guilt. Whether the penalty imposed by the trial court should be modified.
Ruling
The Supreme Court affirmed the conviction for rape but commuted the penalty from death to reclusion perpetua, and increased the moral damages to P30,000.00.
Ratio Decidendi
On the sufficiency of evidence and credibility of the victim's testimony: The Court rejected the appellant's claim that the conviction was based on conjectures. The trial court's conclusions were founded on the direct, positive assertions of the offended party, which were clear, concise, categorical, and bore the imprimatur of sincerity and veracity. The victim's testimony was deemed credible, especially considering her status as a married woman whose chastity had never been questioned, making it highly improbable for her to fabricate such a story that would dishonor her and expose her to public scrutiny. The trial court's assessment of her as unsophisticated and modest further bolstered her credibility. Substantial corroboration was provided by Uldarico Bajar, a disinterested witness who heard the victim shouting for help and saw the appellant jump out of the window naked from the waist down. Bajar also confirmed the victim's injuries, noting bruises and contusions on her face and a torn dress. Further confirmation came from Dr. Rosario P. Mores, who found twelve injuries on the victim's person consistent with her account of being slapped and wrestled with during the assault. On the defense of consent and the appellant's version of events: The appellant's defense of consent, claiming the victim was his former mistress, was rejected. The Court found his version of events, where he allegedly went to drink water and engaged in consensual intercourse, implausible given the victim's struggle, shouts for help, and the appellant's subsequent flight. The appellant's claim that the victim sustained injuries by stumbling was also dismissed as inconsistent with the medical findings and the victim's account of the assault. On the appellant's flight as evidence of guilt: The Court considered the appellant's unexplained flight from his home and hiding for six months as an additional indication of guilt. This abrupt abscondence, which remained uncontroverted, contradicted his protestations of innocence. The Court reasoned that if the relationship were consensual, as claimed, there would have been no need for him to flee in such a manner upon Bajar's arrival. His flight signified an awareness of guilt and consciousness of having no defense to the rape accusation. On the modification of the penalty and damages: The Court affirmed the conviction for rape. However, due to the abolition of the death penalty by the 1987 Constitution, the sentence was commuted to reclusion perpetua. The award for moral damages was increased from P20,000.00 to P30,000.00, in accordance with established doctrine.
Main Doctrine
The conviction for rape is sustained based on the clear, categorical, and sincere testimony of the victim, corroborated by an impartial witness and medical findings, and bolstered by the accused's flight. The penalty of death is commuted to reclusion perpetua due to the abolition of the death penalty.