Fear for life, personal safety ENOUGH to establish rape; physical resistance NOT essential

The argument that complainant did not exert sufficient resistance is bereft of merit for in rape cases it is not necessary that the victim should have resisted unto death. Physical resistance need not be established in rape when intimidation is exercised upon the victim and the latter submits herself, against her will, to the rapist's embrace because of fear for life and personal safety. [G.R. No. 116740. November 28, 1996]