G.R. No. 128157. September 29, 1999 (Case Brief / Digest)

### Title: People of the Philippines vs. Manuel Manahan

#### Facts
Teresita Tibigar, a 16-year-old waitress at the Espiritu Canteen in Dagupan City, alleged that she was raped by Manuel Manahan, the brother-in-law of the canteen owner. On January 5, 1995, at around 2:00 AM, while Teresita was sleeping, Manahan allegedly forced himself on her, covering her mouth and forcibly spreading her legs despite her resistance. The encounter resulted in her pregnancy, leading her to report the incident after returning home. Manahan, however, claimed they were lovers and that their sexual interactions were consensual.

Procedurally, after Teresita’s pregnancy was discovered, her family took her to a hospital and subsequently to the police. A complaint was filed, leading to Manahan’s arrest. He was initially released but was re-arrested and detained. The case was tried in the Regional Trial Court (RTC) of Dagupan City, where Manahan was found guilty of rape and sentenced to death. Upon appeal, the case was brought before the Supreme Court for automatic review.

#### Issues
1. Whether the sexual encounter between Manuel Manahan and Teresita Tibigar constituted rape.
2. The credibility of the “sweetheart theory” posited by the defense.
3. The appropriateness of the death penalty imposed by the RTC.
4. The legality of requiring Manahan to acknowledge and support the offspring from the rape.

#### Court’s Decision
**Issue 1**: **Constitution of Rape**
– The Supreme Court upheld the RTC’s findings that Teresita Tibigar was forcibly raped by Manuel Manahan. Her detailed and consistent testimony, corroborated by her immediate complaint after discovering her pregnancy, convinced the Court of the non-consensual nature of the intercourse. The defense’s narrative lacked substantive evidence to prove a consensual relationship.

**Issue 2**: **Credibility of Sweetheart Theory**
– The Court found no credible evidence supporting Manahan’s “sweetheart theory.” His failure to present substantial evidence, such as love notes or other romantic mementos, and the categorical denial by Teresita, led the Court to disbelieve his claim. Testimonies from defense witnesses were deemed unreliable and failed to establish any romantic relationship.

**Issue 3**: **Appropriateness of the Death Penalty**
– The Supreme Court disagreed with the RTC’s imposition of the death penalty. The rape did not meet any of the qualifying circumstances under Article 335 of the Revised Penal Code as amended by RA 7659. Consequently, the penalty was reduced from death to reclusion perpetua (life imprisonment).

**Issue 4**: **Acknowledgment and Support of Offspring**
– The Court ruled that Manahan, being legally married, could not be compelled to acknowledge the offspring. However, the order for Manahan to support the child, Melanie Tibigar, was affirmed, aligning with the legal requirement to support any offspring resulting from the crime.

#### Doctrine
1. **Rape and Use of Force**: Sexual intercourse by means of force overrides claims of consensual relationships without substantial evidence. Resistance and non-consent are established through credible and consistent witness testimony.
2. **Penalties for Rape**: The imposition of the death penalty requires specific qualifying circumstances to be present, as outlined in Article 335 of the Revised Penal Code. In the absence of such qualifiers, reclusion perpetua is the appropriate penalty.
3. **Acknowledgment Restrictions**: A married individual cannot be mandated to acknowledge offspring from illicit relations, but must provide financial support.

#### Class Notes
– **Elements of Rape** (Art. 335 RPC): 1) Force/Intimidation, 2) Deprivation of reason/unconsciousness, 3) Victim under 12 or demented.
– **Qualifying Circumstances for Death Penalty in Rape**: Use of deadly weapon, multiple offenders, resulting homicidal insanity, under-age victim with familial relation, police custody, public view by family, religious child, AFP/PNP perpetrator, AIDS afflicted offender.
– **Legal Provisions**:
– **Intimidation and Force**: Essential in proving rape, demonstrated through consistent victim resistance.
– **Penal Adjustments**: Death penalty requirements are stringent; default to life imprisonment without qualifiers.
– **Support Obligations**: Legal support for offspring irrespective of parental acknowledgment restrictions for married perpetrators.

#### Historical Background
This case reflects the judicial rigor in evaluating rape allegations, particularly the stringent standards for imposing the death penalty. It illustrates the complexities of assessing credibility and the courts’ careful adherence to statutory requirements for severe punishments. The decision underscores societal views on honor and the protection of minors, particularly young Filipina women, who may face significant cultural and familial pressures.


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