Title
People vs. Alvarado, Jr.
Case
G.R. No. L-29230
Decision Date
Jul 25, 1983
Armed robbery, rape, and physical injuries in Baybay, Leyte; accused convicted, penalties modified; alibis dismissed, complex crime principles applied.
A

Case Digest (G.R. No. L-29230)

Facts:

  • Parties and charges
    • The People of the Philippines charged Diosdado Alvarado, Jr., Sofronio Pegares, Justinianio Oracion, and Salazar Aragon with Robbery in Band with Rape and Multiple Physical Injuries.
    • Complaint alleged entry by force on February 6, 1967, at Baybay, Leyte, with theft of P12,730.00 and commission of rape upon two victims and injuries upon four persons.
  • Circumstances of the intrusion and theft
    • At about 2:00 a.m., the accused, each armed with a revolver, bored through the kitchen door and entered the house of spouses Alfonso Mesario and Celerina Saladores.
    • Four accused entered the room where several persons slept, ransacked aparadores and a trunk, and took P4,000.00 and jewelry from Dionisia Saladores and P8,200.00 from Celerina Saladores.
  • Acts of violence, rape and flight of victims
    • Accused assaulted Dionisia Saladores; Sofronio Pegares struck her with a revolver.
    • Magdalena Arejola was dragged from under a bed by Justiniano Oracion, taken to a coconut plantation, and raped after forcible removal of her panty.
    • Flora Prado was dragged from under a bed by Salazar Aragon, brought to the kitchen, forcibly stripped and raped; she later felt vaginal pain and had positive sperm-cell findings.
    • Simeon Mesario escaped through a window, was fired upon, sustained a gunshot wound and injuries from landing after the jump.
  • Medical examinations and findings
    • Dr. Francisco Isidro found contusions, abrasions and a small laceration on Dionisia Saladores, healing in 10–15 days.
    • Dr. Leticia Lacerna Perez found abrasions on Flora Prado’s external genitalia and positive sperm cells.
    • Dr. Victorino Abrasaldo found thoracic concussion and contusion on Flora Prado; Dr. Emilio Martinez found gunshot wound and contusions on Simeon Mesario.
    • Dr. Abrasaldo found extensive contusions on Celerina Saladores, healing in 6–9 days.
  • Trial court verdict and sentences
    • The Court of First Instance of Leyte convicted:
      • Justinianio Oracion of robbery in band with rape and multiple injuries; imposed reclusion perpetua plus three separate indeterminate penalties for injuries and indemnity P20,000 to Magdalena Arejola.
      • Salazar Aragon of robbery in band with rape and multiple injuries; imposed reclusion perpetua plus three separate indeterminate penalties and indemnity P10,000 to Flora Prado.
      • Diosdado Alvarado, Jr. and Sofronio Pegares convicted of robbery in band with multiple injuries; each given three separate indeterminate penalties.
    • Trial court ordered joint and several indemnities of P2,250 to Dionisia and P2,000 to Celerina, and assessment of four-fifths of costs.
    • Trial court directed successive service of sentences under Art. 70, Revised Penal Code subject to a forty-year ceiling, and denied one-half credit under Art. 29, Revised Penal Code...(Subscriber-Only)

Issues:

  • Issues as framed on appeal
    • Whether the evidence established beyond reasonable doubt the guilt of Justinianio Oracion and Sofronio Pegares for the offenses charged.
    • Whether the trial court erred in imposing multiple separate indeterminate penalties for injuries sustained during the robbery.
    • Whether the injuries inflicted during the robbery justify separate penalties distinct from the penalty for robbery in band with rape or robbery in band with violence.
    • Whether appellants’ alibi defenses were sufficient to create reasonable doubt.
    • Whether credit for pr...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.