People of the Philippines v. Lito Egan Alias Akiao, G.R. No. 139338 (2002)

A 36-year-old member of the Manobo indigenous people was accused of abducting a 12-year-old girl from the community, forcing her to accompany him to various locations, and raping her. He argued that he and the victim were properly engaged under Manobo traditions because the victim’s father allegedly accepted a dowry in exchange for the marriage. He was ultimately convicted of forcible abduction with rape, which he subsequently appealed. The Supreme Court affirmed the conviction for forcible abduction, explaining that an engagement, even one by virtue of dowry, did not negate the commission of a forcible abduction. Further, the Supreme Court emphasized that, as a minor, the victim could not consent to marriage. However, the Court also found that while the prosecution presented sufficient evidence of sexual abuse, they failed to do so for the crime of rape. The Court modified his conviction to forcible abduction, changing his sentence to a maximum of approximately 14 years of imprisonment and requiring him to pay the victim PHP 50,000.00 in damages.

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  • 2002

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