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JurisprudenceG.R. No. 177354 -

G.R. No. 177354 - PEOPLE OF THE PHILIPPINES, VS. RICARDO TALAN Y DOE @ CARDING.D E C I S I O N - Supreme Court E-Library

Cited Laws

RA 424RA 412RA 827RA 675RA 168RA 159
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TL;DR — Ruling

WHEREFORE , the prosecution having duly proved the guilt of the accused in these two cases for forcible abduction with rape, this court finds accused RICARDO TALAN y DOE Alias "Carding" GUILTY of the crimes as charged and hereby imposes against said accused the supreme penalty of DEATH in Criminal Case No. L-3373 and the penalty of RECLUSION PERPETUA in Criminal Case No.

Decision

Ruling

WHEREFORE , the prosecution having duly proved the guilt of the accused in these two cases for forcible abduction with rape, this court finds accused RICARDO TALAN y DOE Alias "Carding" GUILTY of the crimes as charged and hereby imposes against said accused the supreme penalty of DEATH in Criminal Case No. L-3373 and the penalty of RECLUSION PERPETUA in Criminal Case No. L-3599 and in line with recent jurisprudence where the death penalty is imposed he is hereby ordered to indemnify the victim [AAA], the amount of Seventy[-]Five Thousand Pesos (P75,000.00) as civil indemnity in Criminal Case No. L-3373 and Fifty Thousand Pesos (P50,000.00), as civil indemnity in Criminal Case No. L-3599 and the further sum of One Hundred Thousand Pesos (P100,000.00) as moral damages in these two cases. [5] On appeal, Talan claimed that the trial court erred in finding him guilty beyond reasonable doubt of two counts of forcible abduction with rape: (1) the trial court relied solely on AAA's testimony as the basis for its judgment; (2) that AAA did not cry for help while Talan was bringing her to Santa Elena, Camarines Norte, was improbable; and (3) denial was a valid defense. Talan also claimed that, assuming that he was indeed guilty of the charges, the trial court erred in considering the qualifying circumstance of relationship in Criminal Case No. L-3373. The Court of Appeals' Ruling In its 30 November 2006 Decision, the Court of Appeals affirmed the trial court's Joint Judgment with modification: WHEREFORE , premises considered, herein appeal is hereby DISMISSED . The assailed Decision is hereby AFFIRMED with MODIFICATION , the penalty of Death imposed by the court a quo in Criminal Case No. L-3373, is reduced to Reclusion Perpetua . Likewise, the civil indemnity to be awarded to the Victim in Criminal Case No. L-3373 is hereby reduced to Fifty Thousand (Php 50,000.00) Pesos . [6] Hence, this appeal. The Court's Ruling An appeal in a criminal case opens the entire case for review. The Court can correct errors unassigned in the appeal. [7] The Court finds Talan guilty beyond reasonable doubt of two counts of rape. Forcible abduction is absorbed in the crime of rape if the real objective of the accused is to rape the victim. [8] Based on the records, the real objective of Talan was to rape AAA when he brought her to the place with banana trees and to Santa Elena, Camarines Norte. Talan claimed that the lower courts erred in relying solely on AAA's testimony. The Court is not impressed. In rape cases, the credibility of the victim's testimony is almost always the single most important factor. When the victim's testimony is credible, it may be the sole basis for the accused's conviction. [9] The evaluation of the credibility of the witnesses' testimonies is a matter best left to the trial court because it has the opportunity to observe the witnesses and their demeanor during the trial. The Court accords great respect to the trial court's findings, unless the tria