May an accused be convicted of rape if the victim lost consciousness prior to the rape?
Yes. In the case of People v. Romel Vale y Palmaria, G.R. No. 256253, January 11, 2023, the Court convicted the accused based on circumstantial evidence that established among others; that it was he who grabbed the victim and dragged her to an isolated area, removed her pants and tied them around her neck until she lost consciousness; that after waking up, the victim felt pain in her vagina with blood oozing therefrom, and she already had no underwear; coupled with the fact that according to the medico-legal report, she sustained a hymenal laceration. Further, the Court said:
“Jurisprudence is replete with cases of rape where the victim was unconscious, but the accused was nevertheless found guilty on the basis of circumstantial evidence. Circumstantial evidence of rape is usually necessary because the crime is generally unwitnessed and very often only the victims are left to testify for themselves. On this score, the court has consistently held that sufficient and competent circumstantial evidence may warrant the conviction of the accused of rape, provided that: (a) there was more than one circumstance; (b) the facts from which the inferences were derived were proved; and (c) the combination of all the circumstances was such as to produce a conviction beyond reasonable doubt. Here, as deftly explained by the CA, the unbroken chain of circumstances was so credible that it led to no other conclusion but that the elements of the crime exist, and that the perpetrator was Vale.” (Citations omitted)