Cited Laws
TL;DR — Ruling
The appeal is bereft of merit.
accordingly, sentenced them to suffer the penalty of reclusion perpetua and ordered them to pay AAA, jointly and severally, the amounts of P50,000.00 as civil indemnity and P50,000.00 as moral damages. Further, the RTC found Cahipe not guilty of the crime of Rape in Crim. Case No. 97-02-77 and, accordingly, acquitted him due to insufficiency of evidence. [12] In finding the guilt of accused-appellants, the RTC held that AAA's testimony, as well as the medico-legal report, established that on December 5, 1996, accused-appellants intercepted AAA, threatened her with a bladed weapon, dragged her to a nearby cottage, undressed her, bound her, and took turns raping her. The RTC did not lend credence to accused-appellants' defense of denial and alibi, in light of the positive assertions made by AAA, and considering that it was not physically impossible for them to have been at the place of the crime on the date of the incident. [13] However, as regards the second count of Rape against Cahipe, the RTC opined that it would be unusual for AAA, who had just been raped and left alone in the cottage, to not attempt to escape or shout for help when she was being transported to Ostero's store and back to the cottage, observing that AAA had to pass Ostero's house before reaching the latter's store. According to the RTC, these pose serious doubts as to the existence of the second rape charge, thus, necessitating its dismissal. [14] Dissatisfied, accused-appellants appealed their conviction to the CA. The CA Ruling In a Decision [15] dated April 24, 2014, the CA affirmed accused-appellants' conviction with modification ordering the accused-appellants to jointly and severally pay AAA the amount of P30,000.00 as exemplary damages, in addition to the other amounts already awarded, and imposed interest at the rate of six percent (6%) per annum on all the monetary awards from the date of finality of its Decision until fully paid. [16] Agreeing with the RTC's findings, the CA ruled that AAA's categorical and straightforward testimony prevailed over accused-appellants' denial and alibi. It observed that accused-appellants were in the vicinity of the locus criminis at the time of the incident, and that the two could easily reach the cottage where the rape occurred. [17] Thus, it concluded that accused-appellants' actions fell squarely within the definition of Rape under Article 266-A of the RPC, noting that accused-appellants had carnal knowledge of AAA, and such was attained through force, threat, or intimidation. [18] Aggrieved, accused-appellants filed the instant appeal. The Issue Before the Court The issue for the Court's resolution is whether accused-appellants' conviction for Rape should be upheld. The Court's Ruling The appeal is bereft of merit. At the outset, it must be stressed that in criminal cases, an appeal throws the entire case wide open for review and the reviewing tribunal can correct errors, though unassigned in the appealed judgment, or even reverse
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