### Facts:
On July 6, 1999, Alejandro Calongui y Lopez was charged with two counts of rape against Marinel O. Calongui, his 13-year-old first cousin, alleged to have occurred on January 1 and September 26, 1998, in Pili, Camarines Sur. The case was filed in the Regional Trial Court of Pili, Camarines Sur (RTC), docketed as Criminal Case Nos. P-2813 and P-2814. Calongui pleaded not guilty, leading to a joint trial. The prosecution presented testimonies from the victim Marinel, her brother Noel, their mother Gracia, and Dr. Salvacion Pantorgo, who examined Marinel. The RTC found Calongui guilty, sentencing him to reclusion perpetua for each count and ordering him to pay damages. Calongui appealed to the Supreme Court, which transferred the case to the Court of Appeals (CA) per *People v. Mateo*. The CA affirmed the RTC’s decision with minor modifications. Calongui then appealed to the Supreme Court on the grounds that the prosecution failed to prove his guilt beyond reasonable doubt.
### Issues:
1. Whether the testimonies of the prosecution witnesses were credible and sufficient to establish the guilt of the appellant beyond reasonable doubt.
2. Whether the defense of consensual sexual intercourse due to an alleged romantic relationship between Calongui and Marinel is tenable.
3. Whether the aggravating circumstances stated, such as dwelling, nighttime, and relationship, were valid and justified the award of exemplary damages.
### Court’s Decision:
The Supreme Court denied Calongui’s appeal. The Court found the testimonies of the victim and the witnesses credible, affirming the factual findings of the RTC and the CA. It held that the defense of consensual sex was not substantiated with compelling evidence and therefore cannot be considered. The Court found no aggravating circumstances that would warrant the award of exemplary damages and thus deleted the award of exemplary damages but affirmed all other aspects of the CA’s decision.
### Doctrine:
1. The credibility of the victim’s testimony is crucial in rape cases, and when found credible by the trial court, it is generally upheld by appellate courts.
2. A claim of consensual sex or a romantic relationship between the accused and the victim in rape cases requires compelling evidence beyond mere allegations to be considered.
3. Aggravating circumstances must be explicitly stated and proven to justify the award of exemplary damages in criminal cases.
### Class Notes:
– **Rape through Force or Intimidation**: The elements include the use of force, threats, or intimidation to compel the victim to engage in sexual intercourse against her will.
– **Consent in Rape Cases**: Consent or the existence of a romantic relationship does not negate the act of rape if it is obtained through force, threats, or intimidation.
– **Exemplary Damages in Rape**: These damages can be awarded if there is an aggravating circumstance; however, the absence of such a circumstance or failure to prove the same results in the denial of the award.
– **Credibility of Victims and Witnesses**: The assessment of the credibility of witnesses falls primarily within the domain of the trial court because of its unique position to observe their demeanor, conduct, and attitude.
### Historical Background:
This case underscores the stringent evidentiary standards required in proving the consensual nature of sexual activities in alleged rape cases within the Philippine judicial context. It also emphasizes the importance of credible witness testimonies and the challenge of presenting physical evidence in sexual assault cases. Reflecting the principles set forth in Republic Act No. 8353 (The Anti-Rape Law of 1997), this decision illustrates the evolving understanding and legal interpretation of consent, victim intimidation, and the significance of aggravating circumstances in determining damages.
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