R.A. No. 8353, the Anti-Rape Law of 1997, unequivocally criminalizes marital rape, and the archaic doctrine of irrevocable implied consent to sexual intercourse within marriage is rejected; therefore, a husband can be convicted of raping his wife if the act is committed through force, threat, or intimidation, just like any other perpetrator, without requiring different elements of the crime or standards of proof.

The accused-appellant, Edgar Jumawan, and the private complainant, KKK, were married in 1975, raised four children, and established several businesses primarily managed by KKK. While their conjugal intimacy was initially fulfilling, the accused-appellant reportedly became sexually brutal starting in 1997, foregoing foreplay and causing physical pain, leading KKK to resist, which resulted in threats. In 1998, quarrels increased, often initiated by the accused-appellant complaining about KKK's preoccupation with their businesses' financial problems and her alleged failure to attend to him, stating a woman's place was at home and in bed.

• On October 16, 1998, after prayers, KKK went with the accused-appellant (her husband) to their bedroom but chose to rest on a separate cot due to headache and abdominal pain related to impending menstruation.
• Angered by her refusal to lie on the matrimonial bed, the accused-appellant threw the cot, causing KKK to fall; terrified, she moved to the bed.
• The accused-appellant initiated sexual advances by tapping her lap; KKK refused, stating she was unwell.
• He became insistent, forcibly pulled down her panties tearing them at the sides when she resisted by holding onto them, and refused to let her bend her legs.
• He raised her daster, spread her legs, pinned her hands, rested his legs on hers, and penetrated her despite her continued protests and shouts.
• Their daughters, MMM and OOO, heard the commotion; MMM went upstairs, knocked and kicked the door, asking why her mother was crying.
• The accused-appellant partially opened the door, told MMM not to interfere ("family trouble"), but MMM persisted and entered upon seeing KKK crouching and crying on the bed, noting her torn underwear.
• The accused-appellant initially blocked their exit, but MMM helped KKK push past him and escape to the girls' bedroom, where KKK told them her husband had forced her.
• On October 17, 1998, KKK decided to sleep in the children's room; the accused-appellant entered, demanded she sleep in their room, and scoffed when she refused.
• He returned minutes later, infuriated, lifted KKK from the bed, attempted to carry her out, and tore her short pants when she resisted.
• MMM intervened ("Pa, don't do that..."), but the accused-appellant yelled he was the head of the family and could have sex with his wife even in front of them, ordering the daughters out.
• Alone with KKK, he forcibly pulled off her shorts and panties despite her pleas that her body was still aching, removed his own shorts and briefs, flexed her legs, held her hands, mounted her, and had intercourse.
• He then left the room laughing and stating, "[I]t's nice, that is what you deserve because you are [a] flirt or fond of sex."
• The daughters found KKK disheveled, and she again told them she had been forced by their father.

• The accused-appellant committed two counts of rape against his wife, KKK, on October 16 and 17, 1998, through the use of force and intimidation, violating R.A. No. 8353.
• KKK provided clear, consistent, straightforward, and credible testimony detailing the non-consensual sexual acts, her resistance, and the force employed by the accused-appellant.
• The testimonies of the daughters, MMM and OOO, corroborated KKK's account regarding the circumstances surrounding the incidents, including hearing her cries, seeing her distress, the torn clothing, and her immediate disclosure of being forced.
• Physical evidence, such as KKK's torn panties and shorts, supported her claim of force and resistance.
• Under R.A. No. 8353, marital status does not preclude a rape conviction; consent must be present for each sexual act and cannot be presumed or irrevocably implied by marriage.
• The accused-appellant's defense of alibi was weak, not proving physical impossibility of being at the crime scene.
• The accused-appellant's claims of ill motive (revenge over finances, fabricated extra-marital affairs) were unsubstantiated, illogical, and failed to discredit KKK's testimony.
• The delay in filing the rape complaint was sufficiently explained by KKK's initial lack of awareness that marital rape was legally punishable, only learning about it from the prosecutor when filing other charges.

• The accused-appellant denied the charges of rape, claiming the allegations were fabricated by KKK.
• He invoked the defense of alibi, asserting he was in Dangcagan, Bukidnon, on October 16 and 17, 1998, attending to a broken truck and hauling corn, corroborated by his driver, Ryle Equia.
• He argued that KKK filed the charges as revenge because he took over control of their businesses due to her alleged mismanagement of funds and because she wanted to cover up her own extra-marital affairs.
• He implicitly argued for a marital exemption, suggesting that sexual intercourse is a mutual right and obligation in marriage and that consent should be presumed, requiring higher standards of proof for force or lack of consent in marital rape cases.
• KKK's voluntary act of going to the conjugal bedroom on October 16 indicated consent.
• The lack of vigorous physical resistance, the absence of a medical certificate showing injuries, and the absence of blood traces negated the claim of force and non-consent.
• The delay in reporting the alleged rapes cast doubt on the veracity of the complaint.

• Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for two counts of rape against his wife, KKK.
• Whether R.A. No. 8353 (Anti-Rape Law of 1997) recognizes and penalizes marital rape, thereby abrogating the marital exemption rule or the theory of implied consent to sexual intercourse in marriage.
• Whether the prosecution proved beyond reasonable doubt the elements of rape, specifically the use of force or intimidation and the lack of consent, despite the marital relationship between the accused and the victim.
• Whether the accused-appellant's defenses, particularly alibi and the alleged ill motives of the victim, were sufficient to overturn the finding of guilt.

• The Supreme Court affirmed the Decision of the Court of Appeals with modifications to the damages awarded.
• The Court held that R.A. No. 8353 clearly criminalizes marital rape by removing the previous distinction based on marital status and explicitly referencing the husband as a possible offender in Article 266-C; the legislative intent was to penalize forced sexual intercourse within marriage under the general definition of rape.
• The Court explicitly rejected the archaic irrevocable implied consent theory (Hale's rule), stating marriage does not grant a husband proprietary rights over his wife's body nor serve as a license to rape; consent must be conscious and voluntary for every instance of sexual intimacy.
• Citing principles of human dignity, gender equality (Philippine Constitution, CEDAW), women's human rights (including sexual autonomy), and the Equal Protection Clause, the Court ruled that marital rape cases should not be treated differently from non-marital rape regarding elements or proof.
• The prosecution successfully proved guilt beyond reasonable doubt through KKK's credible, spontaneous, and consistent testimony detailing the force (throwing the cot, forcibly removing clothes, physical restraint) and her lack of consent (repeated verbal refusals, resistance), which was adequately corroborated by her daughters' testimonies regarding the surrounding events and KKK's immediate disclosures.
• The accused-appellant's alibi was correctly rejected as weak because he failed to prove the physical impossibility of being at the crime scene (Cagayan de Oro) while allegedly in Dangcagan, Bukidnon (only 4-5 hours away).
• The accused-appellant's claims of KKK's ill motive (financial issues, alleged affairs) were deemed unsubstantiated, erratic, and insufficient to overcome the positive identification and credible testimony.
• The absence of a medical certificate, significant physical injuries, or blood traces does not negate rape, as these are not essential elements of the crime, and force need not be irresistible but merely sufficient to overcome resistance.
• The penalty of reclusion perpetua for each count was upheld, without eligibility for parole per R.A. 9346. Civil indemnity was adjusted to P50,000, moral damages sustained at P50,000, and exemplary damages set at P30,000, for each count.

• Marital Rape under R.A. No. 8353: Definition: R.A. 8353 criminalizes rape committed by a husband against his wife by removing marital immunity. Application: The Court applied this law to affirm that Jumawan could be, and was, validly convicted for raping his wife, KKK.
• Rejection of Irrevocable Implied Consent Theory (Hale's Rule): Definition: An outdated legal fiction that marriage implies a wife's irrevocable consent to sexual intercourse. Application: The Court explicitly rejected this doctrine, stating consent must be specific to each act and cannot be presumed from marriage, aligning with modern human rights principles.
• Credibility of Victim's Testimony in Rape Cases: Definition: A conviction for rape may be secured based solely on the victim's testimony if it is credible, convincing, consistent with human nature, and unwavering under cross-examination. Application: The Court found KKK's testimony met this standard, forming the primary basis for upholding the conviction, strengthened by corroboration.
• Alibi as a Defense: Definition: A defense alleging the accused was elsewhere during the crime's commission; requires proof of physical impossibility to be at the locus delicti. Application: Jumawan's alibi was rejected for failing to demonstrate that his alleged location (Dangcagan) made it physically impossible to be at the crime scene (Cagayan de Oro) at the relevant times.
• Equal Protection Clause (1987 Constitution, Art. III, Sec. 1): Definition: Guarantees that all persons similarly situated must be treated alike under the law. Application: Used to argue that R.A. 8353's single definition of rape applies equally whether the perpetrator is the husband or a stranger, precluding different standards of proof for marital rape.
• Gender Equality (1987 Constitution, Art. II, Sec. 14; CEDAW): Definition: Principle ensuring equal rights, roles, and opportunities for women and men. Application: The criminalization of marital rape was framed as fulfilling the Philippines' constitutional and international obligations (CEDAW) to eliminate discrimination against women and uphold their dignity.
• Human Rights of Women (Bodily Autonomy & Sexual Health): Definition: Includes the right to control one's own body and make free and responsible decisions regarding sexuality, free from coercion. Application: The Court stressed that marriage does not extinguish these inalienable rights, reinforcing that non-consensual intercourse, even within marriage, violates these rights.

• "Husbands do not have property rights over their wives' bodies. Sexual intercourse, albeit within the realm of marriage, if not consensual, is rape."
• "A marriage license should not be viewed as a license for a husband to forcibly rape his wife with impunity. A married woman has the same right to control her own body, as does an unmarried woman."
• "The explicit intent to outlaw marital rape is deducible from the records of the deliberations of the 10th Congress..."
• "[T]his provision on marital rape, it does not actually change the meaning of rape. It merely erases the doubt in anybody’s mind, whether or not rape can indeed be committed by the husband against the wife." (Quoting legislative deliberations)
• "Women do not divest themselves of such right [to have control over and decide freely and responsibly on matters related to their sexuality] by contracting marriage for the simple reason that human rights are inalienable."

• People v. Liberta (N.Y. Ct. App. 1984): Adopted as key rationale; cited extensively for its rejection of Hale's irrevocable implied consent theory and its reasoning that there is no rational basis for distinguishing between marital and non-marital rape under the law.
• Commonwealth v. Fogerty (Mass. 1857): Referenced as the first US case applying the marital exemption rule, illustrating the historical context the court was departing from.
• People v. Godoy (321 Phil. 279 [1995]): Distinguished; cited by accused-appellant, but the Court found it inapplicable because the victim's testimony in Godoy was weak/inconsistent, unlike KKK's credible testimony here, thus the absence of physical signs had different implications.
• Tsoi v. CA (334 Phil. 294 [1997]): Referenced to emphasize that sexual intimacy in marriage should be mutual, spontaneous, and based on love, contrasting with the coercion present in this case.
• City of Manila v. Hon. Laguio, Jr. (495 Phil. 289 [2005]): Cited for the definition and principle of the Equal Protection Clause applied in the context of treating marital and non-marital rape alike.
• People v. Mateo (433 SCRA 640 [2004]): Cited regarding the procedure for automatic review in death penalty cases (although applied here for reclusion perpetua review).
• People v. Cabalquinto (533 Phil. 703 [2006]): Cited regarding the rule protecting the privacy/identity of rape victims.
• Various Philippine Rape Cases (e.g., Publico, Agustin, Sison, Estoya, Dimanawa, Magtibay, Baltazar, Bacatan, Cias, Satioquia, Cabtalan, Ogarte, Viojela): Cited primarily as precedent for established rules on witness credibility evaluation, elements of rape (force/intimidation, lack of consent), the weakness of alibi, irrelevance of medical certificates/resistance levels, and awarding of damages in rape convictions.

• Revised Penal Code (RPC), Art. 266-A (as amended by R.A. 8353): Defined the crime of rape; applied to determine the elements and commission of the offense.
• Revised Penal Code (RPC), Art. 266-B (as amended by R.A. 8353): Provided the penalty for rape (reclusion perpetua); applied to impose the sentence.
• Revised Penal Code (RPC), Art. 266-C (as amended by R.A. 8353): Explicitly mentioned "legal husband who is the offender"; cited as crucial evidence of legislative intent to criminalize marital rape.
• Republic Act No. 8353 (Anti-Rape Law of 1997): The governing law; cited throughout as having removed the marital exemption and reclassified rape as a crime against persons.
• Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004): Cited as further legislative affirmation that rape within marriage constitutes sexual violence.
• 1987 Constitution, Art. II, Sec. 11 (Human Dignity): Cited as basis for rejecting doctrines that treat women as property.
• 1987 Constitution, Art. II, Sec. 14 (Gender Equality): Cited to support the invalidation of the marital exemption rule.
• 1987 Constitution, Art. III, Sec. 1 (Equal Protection): Applied to argue against different standards for marital rape.
• Family Code, Art. 68 (Mutual Obligations): Contrasted with the non-consensual acts committed by the accused.
• Rules of Criminal Procedure, Rule 110, Sec. 14 (Amendment of Information): Referenced by the CA (and implicitly accepted by SC) regarding the validity of the amended informations.
• Republic Act No. 9346: Applied to state that the accused-appellant is ineligible for parole.
• Act No. 4180 (Indeterminate Sentence Law): Mentioned as the law under which parole is generally granted, but made inapplicable here by R.A. 9346.
• UN Convention on the Elimination of all Forms of Discrimination Against Women (CEDAW): Cited extensively as an international commitment obligating the Philippines to eliminate discrimination, including practices based on stereotyped roles, supporting the rejection of marital immunity.
• UN Declaration on the Elimination of Violence Against Women: Cited as explicitly recognizing marital rape as a form of gender-based violence.
• Universal Declaration of Human Rights (UDHR), Art. 1: Cited for the principle of inherent dignity and equal rights.
• R.A. No. 9710 (The Magna Carta of Women), Sec. 3: Cited for the principle that human rights are universal and inalienable, applying equally to women.