People v. Danguilan
REITERATIONFacts
The Antecedents: The accused, Elmer Danguilan, was convicted of rape by the Regional Trial Court. The complainant, Marilou P. Carag, alleged that on May 19, 1979, Danguilan, armed with a bolo, forced her to have sexual intercourse with him after stabbing her suitor, Jun Biete. Danguilan admitted to the sexual intercourse but claimed it was consensual as Marilou was his mistress and they had a prior intimate relationship. He also claimed he stabbed Biete for attempting to molest his sister, Vin. Procedural History: The Regional Trial Court convicted Elmer Danguilan y Lasam for the crime of rape. The case was elevated to the Supreme Court on appeal. The Petition: The accused-appellant sought to overturn his conviction for rape.
Issue(s)
Whether the accused-appellant is guilty of the crime of rape. Whether the defense of the accused that the complainant was his mistress negates the crime of rape.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellant guilty of rape. The Court increased the indemnity to be paid to the private complainant from P30,000.00 to P40,000.00.
Ratio Decidendi
On the guilt of the accused-appellant for rape: The Court found the prosecution's evidence convincing that Marilou was forcibly taken as a hostage after Jun Biete was stabbed by the accused. It was established that at the house of Silverio Paras, she was forced to have intercourse with the accused by means of threat and intimidation. Therefore, the crime of rape was undeniably consummated because Marilou did not submit to the accused of her own free will. The Court noted that the stabbing of Jun Biete appeared to be a result of an intense desire by the accused to have sexual access to Marilou. Even if Biete was stabbed for attempting to molest Vin, the accused had no reason for running off with Marilou and taking her against her will. The Court reiterated the principle that consent obtained by fear of personal violence is no consent at all, and that mental and moral coercion can render an accused guilty of rape. On the defense of the accused that the complainant was his mistress: The Court correctly treated the defense of the appellant that Marilou was his mistress as a shallow alibi of a desperate person. The Court cited People v. Taduyo and People v. Partulan, emphasizing that proof of a prior history of a relationship, even a common-law marital relationship, will not prevail over clear and positive evidence of copulation by the use of force or intimidation. The Court found no credible evidence whatsoever that Marilou was a mistress of her aunt's husband. The defense's version was found to be improbable and inadequate, lacking corroboration from credible witnesses. The Court also noted the inconsistencies in the defense witnesses' testimonies, which further strained its credulity. The Court concluded that the testimonies of the accused and his sister, alluding to Marilou as a woman of low morals, had no positive effect on the Court's decision.
Main Doctrine
The Court affirmed the conviction for rape, holding that the prosecution evidence was convincing that the victim was forcibly taken and compelled to have intercourse through threat and intimidation, thus consummating the crime. The defense of the accused, claiming the victim was his mistress, was rejected as a shallow alibi.