Case Digest: PEOPLE OF THE PHILIPPINES v. RODRIGO “RUDY” OPELIÑA et al. 412 SCRA 343 (2003)

PEOPLE OF THE PHILIPPINES v. RODRIGO “RUDY” OPELIÑA et al. 412 SCRA 343 (2003)

Proof of injury is not an essential element in proving the crime of rape. Private complainant Merrylin Rambuyon, who was then a minor, was hired as househelper by the Spouses Rodrigo “Rudy‖ Opeliña and Mary Rose Leones Opeliña. One night, she was awakened by Mary Rose and was told to go inside the bedroom of the Spouses. Upon entering the room, the spouses undressed themselves. Then, Rudy had a sexual intercourse with complainant Merrilyn. All this time, Mary Rose was by Merrilyn‘s right side, holding her down and telling her to bear the pain. The following day, Merrilyn stayed outside the house when the father of Mary Rose called her, she did not respond prompting the latter to pull her hair and smash her head to the wall. Inside the house, Mary Rose told her that she would report her to the police for leaving her baby unattended. Due to the event, Merrilyn went to the police station to report the rape and the physical abuse but she saw Mary Rose in the station who just blottered her. Afraid of what might happened, she only reported the physical abuse. On her way home, the taxi driver heard what Merrilyn and her friend was talking about. He then brought them to a radio station where Merrilyn told what really transpired. Spouses Opeliña denied the accusation of rape, telling that it was a consented sex because Merrilyn wanted to abort her baby by having sexual intercourse with Rudy. They also contend that the reporting of the rape was only an afterthought of Merrilyn and that she really consented to the sex which can be proven that no extra-genital injuries were found. However, the Regional Trial Court found the spouses guilty of the crime of rape with conspiracy. 

ISSUE:

Whether or not the Spouses Opeliña are guilty of rape

HELD:

That no extra-genital injuries were noted in Merrilyn does not necessarily negate the occurrence of rape, proof of injury not being an essential element thereof. Nor does Merrylin’s resumption of discharging her duties as househelper after the rape took place militate against the commission of rape, there being no standard form of human behavioral response when one has just been confronted with an experience as heinous as the crime of rape, not to mention the fact that not every victim of a crime can be expected to act reasonably and conformably with the expectation of mankind. As for Spouses Opeliña’s branding as mere afterthought the filing of the rape charge against them, the Court is not persuaded. For Merrylin gave a credible explanation why she failed to immediately report the rape incident. In the instant case, it was established by the prosecution that Mary Rose summoned Merrylin into their bedroom, locked the door to prevent her escape, pinned her down while Rogelio had sexual intercourse with her, told her thrice to just bear the pain, and cautioned her not to divulge what transpired among them. Clearly, Spouses Opeliña conspired in the commission of the rape.