People v. Fausto
REITERATIONFacts
The Antecedents: The appellant, Fernando Fausto, a married man, was accused of forcible abduction with rape of Silveria Somera, a 15-year-old married woman. Silveria and her husband had been living with Fausto's family for two months prior to the incident, but left due to suspicions of an illicit relationship between Silveria and Fausto. On August 2, 1927, Silveria left a field where she was working, claiming a headache. She testified that Fausto met her, took her to a secret place, violated her, and then kept her in a camarin for about four days, repeatedly having intercourse with her. She claimed she was given nothing to eat or drink during this time. Afterward, Fausto took her to the home of Pablo de los Santos, where she stayed for another three days. She escaped when Fausto traveled to Quezon and reported the incident to a neighbor, claiming she was raped. Procedural History: The Court of First Instance of Nueva Ecija found the appellant guilty of forcible abduction with rape and sentenced him to imprisonment, to endow the injured party, and to pay costs. The Petition: The appellant appealed the judgment of conviction.
Issue(s)
Whether the evidence presented sufficiently proves the crime of forcible abduction with rape. Whether Silveria Somera was a consenting party to the acts complained of. Whether the offense of abduction with consent could be committed given Silveria's marital status and non-virginity.
Ruling
The judgment of conviction is reversed, and the appellant is absolved from the complaint.
Ratio Decidendi
On whether the evidence proves forcible abduction with rape: The Court found Silveria Somera's claim of non-consent to be impeached by several facts. Firstly, she exaggerated the duration of her confinement. Secondly, and more significantly, she had a bundle of female attire with her when she disappeared. The Court reasoned that if Fausto were a rapist, it would be strange for him to provide clothes for the victim. The Court inferred that the clothes were provided by Silveria herself, indicating a pre-arranged plan. Furthermore, disinterested witnesses corroborated that Silveria appeared contented and was carrying a bundle, contradicting her claim of distress and force. The Court concluded that Silveria was a consenting party, making the act not against her will. On whether Silveria Somera was a consenting party: The Court found Silveria's testimony regarding her non-consent to be incredible. The presence of a bundle of clothes, admitted by Silveria, was a crucial factor. The Court believed these clothes were provided by Silveria, suggesting a pre-arranged elopement rather than an abduction. The testimony of witnesses who saw her with a bundle and exhibiting a contented demeanor further supported the conclusion that she was a consenting party. The Court noted that she had opportunities to escape during the days she was allegedly held captive. On whether abduction with consent could be committed: The Court held that since Silveria was a married woman and not a virgin, the offense of abduction with consent, as defined under Article 446 of the Penal Code, could not be committed. The Court also reiterated its stance on crimes against chastity, emphasizing that the testimony of the injured woman should not be accepted with precipitate credulity, especially when uncorroborated. The Court highlighted the potential motives for Silveria to fabricate her story, such as avoiding prosecution for adultery and shielding herself from the wrath of her husband or father. The Court also noted that affidavits submitted for a new trial suggested the possibility of illicit relations and a false narrative of being held against her will, further casting doubt on the conviction.
Main Doctrine
The testimony of the injured woman in crimes against chastity should not be received with precipitate credulity, and conviction should not depend on uncorroborated testimony unless sincerity and candor are free from suspicion. In cases involving elopement between married individuals, motives to shield oneself from scorn or punishment may influence testimony.