Case Digest (G.R. No. L-1060)
Facts:
This case involves an appeal filed by the accused Sergio Revilla, Diosdado Guinto, and Luis Bautista against the ruling of the Court of First Instance of Manila. On June 11, 1946, between 2:00 and 3:00 AM, Porfirio Lapena and his wife Amparo Santiago were accosted in their home located at Antipolo Extension No. 1329, Manila. The accused, armed with firearms and knives, entered the residence after questioning Lapena about the presence of police. They threatened the occupants with death and ordered them to lie face down. During this intrusion, Revilla demanded money, which prompted Amparo to instruct Porfirio to surrender their money from a jacket. Afterward, Revilla took Amparo upstairs under the threat of his gun, where he sexually assaulted her. This was followed by both Bautista and Guinto who subsequently violated her as well.
The police arrived at the scene after receiving information regarding ongoing thefts in the Sampaloc district. They arrested the accused in the basem
Case Digest (G.R. No. L-1060)
Facts:
- Chronology and Commission of the Crime
- Between 2:00 and 3:00 AM on June 11, 1946, Porfirio Lapena was outside his residence located at Antipolo Extension No. 1329, Manila, when the accused arrived at the scene.
- On inquiring about their purpose and confirming that no police were present, the accused initiated the criminal act.
- Entry and Acts of Robbery and Sexual Violence
- The accused entered the house:
- Sergio Revilla was armed with a revolver.
- Luis Bautista was similarly armed with another revolver.
- Diosdado Guinto and Hermogenes Tolentino were armed with knives.
- The intruders threatened the residents under a death threat, ordering everyone present to lie face down.
- They demanded money from Porfirio Lapena.
- Lapena replied that his money was in his jacket and instructed his wife, Amparo Santiago, to hand it over.
- Sexual assault committed on Amparo Santiago:
- Sergio Revilla forcibly took Amparo Santiago upstairs, threatened her with his revolver, and, after violent intimidation, committed sexual intercourse.
- Immediately afterward, Luis Bautista and then Diosdado Guinto also committed sexual acts against her under similar conditions of violence and intimidation.
- Post-crime actions:
- After committing the acts of robbery and sexual assault, the accused departed, carrying with them various stolen articles.
- Seized Stolen Items and Apprehension of the Accused
- Items reported stolen from the victim’s residence included:
- A watch valued at P50.
- A pair of earrings worth P40.
- A ring of engagement valued at P22.50.
- A ladies’ ring with a pearl valued at P50.
- A jacket (exhibited as H) valued at P14.
- A bracelet with initials A.S.L., valued at P40.
- A belt, a hunting knife, two distinct shirts (khaki and Palm Beach), an air rifle, a cap, and P50 in cash.
- Between 4:00 and 5:00 AM, police officers Liwanag, Aspeli, and others, acting on reports of a burglary in Sampaloc, arrested:
- Sergio Revilla, Diosdado Guinto, and Luis Bautista at Miguelin Street No. 946.
- On arrest, several items were found in their possession:
- Firearms (a revolver caliber .38 and a pistol caliber .45).
- Ammunition supplies (magazines and balled packages along with additional items such as a pencil, three watches, and sewing machine parts).
- Statements, Identification, and Additional Evidence
- Upon arrest, the accused gave statements (exhibits I, J, and K) in which they admitted to the commission of the crime.
- The victims, Porfirio Lapena and Amparo Santiago, positively identified the accused as the perpetrators.
- Physical evidence included:
- The jacket (exhibited H/II) found on Sergio Revilla, identified as belonging to Porfirio Lapena.
- Testimony and physical evidence regarding the condition of items (e.g., a t-shirt used by Revilla to allegedly prove he had been mistreated) which ultimately undermined his claim of having suffered severe abuse.
- Conflicting testimonies were noted regarding the ages of the accused, particularly Luis Bautista, whose age was disputed between his statement to the police and his declaration in court.
- Despite allegations by the accused that their statements were obtained under duress or torture, these claims were contradicted:
- Testimonies of police officers (e.g., Sargento de Policia Versosa) attested that the declarations were given freely and voluntarily.
- Physical evidence (such as the condition of the clothing) lent weight against the claims of mistreatment.
Issues:
- Sufficiency of the Evidence
- Whether the evidence, consisting of victim identification, physical items, and the confessions, sufficiently established the occurrence of the crimes of robbery in quadrilla and sexual assault.
- The credibility and reliability of the victim’s identification in corroborating the involvement of the accused.
- Admissibility and Credibility of Confessions and Alleged Coercion
- Whether the confessions and statements of the accused—allegedly given under duress or as a result of police intimidation—could be considered valid and free from coercion.
- The issue of whether the physical evidence against the accused, including the recovered stolen items and weapons, outweighs the defendants’ claims of having suffered police maltreatment.
- Defense of Alibi and Inconsistencies in Testimonies
- Whether the coartada defense presented by some of the accused (claiming to be elsewhere or only associating with their co-accused after the incident) holds merit in view of the physical and testimonial evidence.
- The significance of discrepancies in the accused’ statements—such as differing accounts regarding age and location during the crime—in undermining their defenses.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)