Case Digest (G.R. No. 107235)
Facts:
People of the Philippines v. Ladislao Abo y de Alday, G.R. No. 107235, March 02, 1994, First Division, Davide, Jr., J., writing for the Court.The prosecution (the People of the Philippines) charged Ladislao Abo y de Alday with rape in an information filed by the Provincial Fiscal of Quezon on August 15, 1986, alleging a forcible carnal knowledge of Adelia Velasco de Chavez on or about May 13, 1986 in Barangay San Agustin, Tiaong, Quezon. Branch 58 of the Regional Trial Court (RTC) of Lucena City tried Criminal Case No. 86-439; on August 27, 1992 the RTC convicted the accused, sentenced him to reclusion perpetua, ordered indemnity of P25,000 to the offended party, and imposed costs.
At trial the prosecution relied principally on the testimony of the offended party, Barangay Captain Armando Barcelona, and Dr. Vicente Umali (the municipal rural health physician). The victim testified that in the early afternoon the assailant came from behind, dragged her into bushes, struck her, threatened to kill her, forced intercourse despite her resistance, and that she fled, reported the incident to neighbors, submitted to a medical exam showing contusions and an abrasion, and the following day recognized the same man in a ricefield and later pointed him out at the police station where she signed a sworn complaint. The trial court found these accounts credible and detailed the sequence of events, the physical marks observed by Dr. Umali, and the circumstances of the identification.
The accused pleaded alibi and presented witnesses (Reynaldo Catibog, Florencio Abo) and other witnesses (Arsenio Arias, Ernesto Dimaculangan, Raul Umali, Patrolman Felino Noguera) to challenge identification and to show alleged ill motive between families. The accused testified he worked on a farm the afternoon of May 13, 1986, was at home after 5:00 p.m., and was later brought to police where the victim identified him. The RTC disbelieved the alibi and defense witnesses, credited the victim’s positive identification and medical evidence, and convicted.
The accused appealed to the Supreme Court contesting (1) the sufficiency and corroboration of the victim’s testimony, (2) the trial court’s treatment of alleged inconsistencies in the victim’s description, (3) the trial court’s rejecti...(Subscriber-Only)
Issues:
- Was the conviction supported by sufficient evidence—specifically, was the victim’s identification of the accused sufficiently credible to sustain a conviction for rape?
- Did the accused's alibi and the testimony of his witnesses create reasonable doubt that would overturn the conviction?
- Was the award of indemnity properly fixed at P25,0...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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