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Cohabitation

People v. Edualino
GR No. 119072
April 11, 1997

PADILLA, J.:

FACTS:
This is a review of the conviction of a rape case filed against Jesus Edualino by the complainant
Rowena Nantiza a married and pregnant woman at the time of the incident.

The complainant version of fact states that she was invited to drink one bottle of beer by then a
drunk Edualino. When she was semi-conscious she was dragged in a place where the evil acts were
consummated.

The accused arguments rely on alternative defenses and alibi, to wit; 1) that there was foreplay and
orgasm that occurred in the alleged consummation and that according to the defense bear the
earmarks of a voluntary and mutual coition of a consensual intercourse 2) that the character of the
complainant is of ill-refute on the basis that no responsible and decent pregnant married woman,
would be out at two (2) o'clock in the morning getting drunk much less would a decent Filipina ask
a man to accompany her to drink beer 3) that the complainant merely concocted the charge of rape
to save her marriage since her husband had found out that she was using drugs and drinking alcohol
and even made a spectacle of herself when she tried to seduce accused-appellant on May 1994
while she was under the influence of drug and alcohol.

ISSUE:
Whether or not the crime of rape was established.

HELD:
The crime of rape was established beyond reasonable doubt.

The court held that the victim Rowena Nantiza's testimony was sufficient to manifest that the carnal
knowledge was without her consent and with due force and intimidation. The court further provides
that a person accused of rape can be convicted solely on the testimony of the victim provided the
testimony is credible, natural, convincing and otherwise consistent with human nature and the
course of things.

On the issue of morality of the complainant, the court pointed out that the moral character of a
rape victim is immaterial in the prosecution and conviction of the accused. The allegation of
drunkenness and being a drug user will not per se preclude a finding that a woman was raped.

The Court ruled that even prostitutes can be the victims of rape.

On the Accused-appellant argument that the charge of rape was concocted by the victim to save
her marriage; the Court did not believe that a married woman would invent a story that she was
raped in an attempt to conceal addiction to drugs or alcohol, in order to save her marriage. The
court cannot understand how a false rape story can save a marriage under the circumstances.