GR L 48010; (July, 1986) (Digest)
G.R. No. L-48010. July 31, 1986.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SANCHO BUDOL y AYENTE and WILFREDO LLAGUNO y BARDIAGO, defendants-appellants.
FACTS
On the evening of September 25, 1977, sixteen-year-old Lyneath Poquiz was cycling home in Mangatarem, Pangasinan, when accused Sancho Budol called to her from the grounds of the Mangatarem Elementary School. Upon entering, Budol and his co-accused Wilfredo Llaguno forcibly pulled her to the back of the building and into a boys’ toilet. Lyneath resisted and shouted for help to no avail. Inside, Llaguno held her hands while Budol slapped, choked, and undressed her. Budol then forcibly had sexual intercourse with her as Llaguno stood guard at the door. Subsequently, Budol brought her to a girls’ toilet, where he again molested her. Meanwhile, Lyneath’s worried parents, after finding her bicycle at the school gate, searched the premises. Her father discovered Budol assaulting Lyneath in the girls’ toilet. Budol fled but was caught and subdued. Lyneath was taken for medical examination, which revealed fresh lacerations consistent with recent sexual intercourse.
The defense presented a different account. Budol claimed he and Lyneath were sweethearts and that their sexual encounter inside the school was consensual. He alleged her father discovered them, became enraged, and that the rape charge was fabricated out of parental anger. Llaguno denied any participation, stating he was merely present and left before any alleged incident occurred. The trial court convicted Budol as principal and Llaguno as an accomplice to rape.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt, particularly challenging the credibility of the complainant’s testimony against the defense of a romantic relationship and consensual sex.
RULING
The Supreme Court affirmed the convictions but modified the award of indemnity and deleted the aggravating circumstances. The Court upheld the trial court’s assessment of Lyneath’s credibility, finding her testimony on the forcible abduction and sexual assault to be clear, consistent, and convincing. The medical evidence, showing fresh hymenal laceration, strongly corroborated her claim of recent defloration. The defense of a sweetheart theory was rejected for being unsupported by credible evidence and inherently implausible given the violent circumstances of the encounter and the immediate outcry. The Court found Llaguno’s actions in initially helping to pull the victim, holding her during the assault, and standing guard constituted indispensable cooperation, rightly qualifying him as an accomplice. However, the Court corrected the trial court’s finding of aggravating circumstances. Nocturnity was not present as the incident began at dusk (6:00 P.M.), which is not considered nighttime for aggravation. The school grounds, though deserted, did not constitute an “uninhabited place” in the legal sense, as it was within the poblacion and not shown to have specially facilitated the crime. The penalty of reclusion perpetua for Budol was affirmed as the proper penalty for simple rape. The civil indemnity awarded to the victim was increased to P20,000.00.
