PEOPLE VS. SANTIAGO No.

27972 October 31, 1927

FACTS:

On November 23, 1926, herein appellant Felipe Santiago raped Felicita Masilang, his
wife’s niece, in an uninhabited place across a river in Gapan, Nueva Ecija. After the
deed, he took her to the house of his brother, Agaton Satiago, who in turn fetched a
protestant minister who there and then officiated the ceremony of their marriage. After
having given money by Felipe, Felicita proceeded home to her father and told what
had just occurred.

ISSUE: Whether or not the marriage executed by the protestant minister is of legal
effect.

HELD: The marriage ceremony was a mere ruse by which the appellant hoped to
escape from the criminal consequence of his act. It shows that he had no bona fide
intention of making her his wife and the ceremony cannot be considered binding on
her because of duress. The marriage was therefore void for lack of essential consent,
and it supplies no impediment to the prosecution of the wrongdoer.
PEOPLE V. MANGITNGIT

FACTS

That sometime during the month of May, 1993, at around midnight, and on or about the
21st day of January, 1999, at around 4:00 o'clock in the morning, the said accused
with lewd design and by means of force, threat and intimidation, did then and there
wilfully, unlawfully and feloniously have carnal knowledge with his own daughter
[AAA],5 15 years of age, against her will and consent to her damage and prejudice.

That on or about the 29th day of January,1999, at around 2:00 o'clock in the morning,
the said accused with lewd design and by means of force, threat and intimidation, did
then and there wilfully, unlawfully and feloniously have carnal knowledge with his own
daughter [CCC], 12 years of age, against her will and consent to her damage and
prejudice.

Issue

Whether or not Mangitngit is guilty of raping his own daughters

Ruling

YES

Courts give full weight and credence to testimonies of child-victims of rape. Youth and
immaturity are generally badges of truth.49 It is highly improbable that 12-year old and
15-year old girl like CCC and BBB would impute a crime as serious as rape to their own
father, undergo the humiliation of a public trial and put up with the shame, humiliation
and dishonor of exposing their own degradation were it not to condemn an injustice
and to have the offender apprehended and punished.

Accordingly, in resolving rape cases, primordial consideration is given to the credibility

of the victim's testimony.41 If the testimony of the victim is credible, natural, convincing
and consistent with human nature, and the normal course of things, the accused may
be convicted solely on the victim's testimony
PEOPLE V. TEOPE

FACTS

Sometime in August, 2000, complainant Alma Agapay, a 22-year old mental retardate,
was on the railroad tracks near their house at Daang Bakal, Public Market, San Pablo
City when appellant approached her and said, "I don’t know you but I know your
mother." He then pulled Alma and brought her inside an old abandoned train car. He
tied her hands above her head and made her lie down on the floor covered with a
flattened carton box. He removed her dress and panties, after which he also
undressed. While holding a knife with his right hand, he kissed her then inserted his penis
into her vagina, causing it to bleed. Alma felt pain. She shouted and tried to fight back
but her efforts were in vain since she could not move her right arm due to a stroke she
suffered before. After raping her three or four times, appellant threatened to kill her and
her mother if she would tell anybody what happened.

ISSUE

Whether or not Teope is guilty of the crime of rape

RULING

YES

It is undisputed that the victim is a retardate or suffering from a sort of mental

deficiency. Her manner of testifying as well as deportment in Court bespeak of her
mental defect. However, the Court has observed that she could perceive and make
known or express her perceptions to others. In the instant case, she clearly explained
her perceptions of what happened when she was ravished sexually by the accused.
Her behaviour at the witness stand pointing to the accused as the one who raped her
and requested that accused be brought to the police and be sentenced to death
were clearly expressed in a straightforward manner, thus the Court was impressed of
her positive identification of the accused.
PEOPLE V. ANTIVOLA

FACTS

By December 1997, Rachel de Guzman was already five years of age..8 In the
afternoon of December 4, 1997, Rachel, together with three other children, were
playing outside. Rachel saw the appellant Rodel (Bungi) Antivola feeding the fishes in
the nearby fishpond.9 The appellant approached Rachel and asked her to go with him
inside his house, telling her that they would play another game. Unsuspecting, she
acceded and went with the appellant.10

Once inside the house, the appellant removed Rachel’s shorts and touched her private
parts. She cried, but the appellant was unmoved. He brought out his penis and inserted
it into Rachel’s vagina, causing the child excruciating pain. After satiating his lust, the
appellant let her go and instructed her to step out.11

ISSUE

Whether or not Antivola is guilty of the crime of rape

RULING

YES

Rachel’s testimony was direct, candid, and replete with details of the rape. She testified
that after touching her private parts, the appellant inserted his penis inside her vagina.

Rachel’s testimony says it all. It is marked by spontaneity, honesty and sincerity. When a
woman, more so if she is a minor, says that she has been raped, she says in effect all
that is necessary to show that rape was committed.38Youth and immaturity are
generally badges of truth and sincerity.39 In rape cases, the testimony of the victim
alone, if credible, is sufficient to convict the accused of the crime. The medical
certificate is presented merely to corroborate the victim’s declaration that she was
sexually molested. In fact, what is more telling in the medical findings proffered in
evidence by the prosecution is the presence of hymenal lacerations in different
positions in the victim’s genitalia which is the best physical evidence of her forcible
defloration.