Case Digest (G.R. No. 251631)
Facts:
People of the Philippines v. Atilano Agaton y Obico, G.R. No. 251631, August 27, 2020, First Division, Peralta, C.J., writing for the Court. The prosecution charged Atilano Agaton y Obico (appellant) together with Edgar Evangelio, Joseph Evangelio and Noel Malpas y Garcia with the special complex crime of Robbery with Rape in an Information dated December 3, 2001, arising from a violent entry into the residence of spouses (identified in the record as BBB and CCC) on October 3, 2001, in Tacloban City, during which jewelry and other valuables were taken and a 17‑year‑old female household member (AAA) was allegedly raped while unconscious.At arraignment Edgar pleaded guilty and appellant pleaded not guilty. The prosecution presented AAA and sought to adopt her earlier testimony from the trial of co-accused Joseph (whose case was previously the subject of People v. Evangelio, et al., 672 Phil. 229). The trial court ordered Edgar’s prior plea of guilty withdrawn and reinstated a plea of not guilty, but later, on June 18, 2016, Edgar and appellant voluntarily pleaded guilty to Robbery only; the trial court found the pleas voluntary. Edgar subsequently died on January 10, 2018, and the trial court dismissed the case against him. Other witnesses presented by the prosecution included BBB, CCC, Dr. Angel Cordero and Police Inspector Aliuro Abuyen; the defense called Edgar and appellant who interposed denial and alibi.
On April 18, 2018, the Regional Trial Court (RTC), Criminal Case No. 2001-12-773, convicted appellant of the special complex crime of Robbery with Rape, imposed reclusion perpetua without eligibility for parole (citing Republic Act No. 9346) and ordered restitution and awards of civil indemnity, moral and exemplary damages. The Court of Appeals (CA), in CA‑G.R. CEB CR. HC No. 02949, affirmed the conviction but modified the damages, increasing awards in accordance with ...(Pro-only)
Issues:
- Did the prosecution prove beyond reasonable doubt that appellant was guilty of the special complex crime of Robbery with Rape?
- If not, should appellant instead be convicted only of Robbery in band and what is the proper penalty and ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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