People v. Blance
REITERATIONFacts
The Antecedents: The accused, Anselmo Blance, a principal teacher in a public school, was charged with raping Maria Bernales, an 18-year-old maiden and a teacher subordinate to him, in the school building on October 4, 1922. The complaint alleged that the act was committed through force and intimidation, against the victim's will. Procedural History: The accused was tried, found guilty of rape, and sentenced to seventeen years and four months of reclusion temporal, with civil indemnity, maintenance for any resulting child, accessory penalties, and costs. The accused appealed the sentence. The Petition: The accused raised three assignments of error: (1) the lower court erred in finding that illicit relations existed prior to the offense; (2) the lower court erred in not permitting questions about the instigators of the prosecution; and (3) the lower court erred in its treatment of defense witnesses.
Issue(s)
Whether the existence of prior illicit relations between the accused and the offended party negates the commission of rape by force and intimidation. Whether the lower court erred in disallowing questions regarding the instigators of the prosecution. Whether the lower court erred in its treatment of the defense witnesses.
Ruling
The Supreme Court affirmed the conviction and sentence imposed by the lower court.
Ratio Decidendi
On the issue of prior illicit relations: The Court held that even admitting that the appellant had been having illicit relations with the offended party for months before the incident, this fact would not constitute a defense if the illicit relations described in the complaint were committed by force and violence and against the will of the offended party. The Court emphasized that the appellant's admission of prior illicit relations was likely made under the belief that it would convince the court that the act in question did not occur by force and violence. Maria Bernales positively swore that she was forced by violence and tried to defend herself, producing a scar on the appellant, which the lower court believed. The Court further stated that the offended party's character, whether chaste or unchaste, constitutes no defense to the charge of rape if force and violence were used. The appellant is equally guilty regardless of the offended party's morals, citing People v. Hartman and McClain on Criminal Law. On the issue of instigators of the prosecution: The Court found no error in the lower court's disallowance of questions concerning the instigators of the prosecution. The record showed that Maria Bernales filed the complaint the morning after the offense, answering the appellant's question. Any further inquiry was deemed unnecessary. On the issue of treatment of defense witnesses: The Court found no merit in the allegation that the lower court erred in its treatment of defense witnesses. An examination of the record clearly refuted the appellant's allegations, showing no attempt by the lower court to intimidate or influence the defense witnesses.
Main Doctrine
The fact that the offended party may have been an unchaste character or had prior illicit relations with the accused does not constitute a defense to a charge of rape if it is proven that the illicit relations described in the complaint were committed with force and violence and against the will of the offended party.