PEOPLE OF THE PHILIPPINES, vs. MANUEL MATRIMONIO Y PADILLA.
- G.R. Number: G.R. No. 82223-24
- Promulgated: 1992-11-13
- Ponente: Davide, Jr., J.
Doctrine
Intimidation may be established by threats and by overpowering moral influence, and can vitiate consent of an infant victim, supporting a rape conviction when proven beyond reasonable doubt.
Relationship between offender and offended party (descendant) is an aggravating circumstance under Article 15 of the Revised Penal Code and should be appreciated against the accused even if not alleged in the information when duly proven without objection.
The Court may impose moral and exemplary damages in crimes against chastity; inability of the convict to pay does not preclude awarding such damages.
Facts
Rowena Matrimonio was 14 years old in December 1985 and lived in poverty; she reported being sexually molested twice and executed a sworn statement at the Western Police District on 25 June 1986, and underwent medico-legal examination with a written report by the Medico-Legal Officer.
The accused was alleged to have committed sexual acts with Rowena on 27 December 1985 and 5 April 1986; he was tried in two criminal cases (Nos. 86-46285 and 86-46286).
The trial court found that Rowena yielded because of intimidation and that the acts were committed against her will; the accused claimed consent.
Issues
Whether appellant committed the crime of rape in Criminal Case No. 86-46285 and in Criminal Case No. 86-46286.
Ruling
The Court affirmed the trial court's convictions: the prosecution proved beyond reasonable doubt that the appellant intimidated Rowena into consummating the sexual acts on 27 December 1985 and 5 April 1986, using threats and overpowering moral influence.
The Court modified the judgment to award moral damages of P50,000.00 and exemplary damages of P25,000.00 to Rowena in each case; costs against the appellant were imposed.
Keywords
mother, criminal, rowena, appellant, father, undersigned, branch, brothers, years, december