Rape Conviction Upheld: The Importance of Victim Testimony and Corroborating Evidence

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G.R. No. 118077, November 21, 1996

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In the Philippines, proving rape beyond a reasonable doubt often hinges on the credibility of the victim’s testimony. But what happens when the defense claims consent? How do courts weigh conflicting accounts and ensure justice is served? This case delves into these critical questions, highlighting the importance of corroborating evidence and the court’s assessment of witness credibility.

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Understanding Consent and the Law on Rape

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Philippine law defines rape as an act committed by a man who has carnal knowledge of a woman under circumstances such as when the woman is deprived of reason or otherwise unconscious, or when the act is committed by means of force or intimidation. The absence of consent is a crucial element. The Revised Penal Code, specifically Article 266-A, outlines the crime of rape and its corresponding penalties.

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The prosecution must prove beyond a reasonable doubt that the act was committed without the woman’s consent. This often involves presenting the victim’s testimony, medical evidence, and other corroborating evidence to support the claim of non-consent. The accused, on the other hand, may present evidence to prove consent or raise doubts about the victim’s credibility.

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Article 266-A of the Revised Penal Code states: “Rape is committed by a man who shall have carnal knowledge of a woman under any of the following circumstances:n1. Through force, threat, or intimidation;n2. When the woman is deprived of reason or otherwise unconscious;n3. When the woman is deceived; orn4. When the woman is in any way deprived of her liberty.”n

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For example, imagine a scenario where a woman goes on a date, consumes alcohol, and later claims she was raped. The court would need to carefully assess her level of intoxication, her ability to consent, and any evidence of force or intimidation used by the man.

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The Case of People vs. Cabaluna: A Story of Deception and Assault

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The case of People vs. Dominador A. Cabaluna revolves around Leticia Abenion, a young woman who worked for the Cabaluna family. Leticia reported feeling ill and was given capsules by Dominador, who claimed they were medicine. According to Leticia, these capsules rendered her unconscious. She later awoke naked in a motel room with Dominador, also partially undressed, and with signs of bleeding from her private parts.

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Dominador, however, claimed that he and Leticia were