Title
People vs. Andaya
Case
G.R. No. 86364
Decision Date
May 6, 1991
Lope Andaya was convicted of raping 14-year-old Irene Pilapil after holding her overnight at his workplace, with the court affirming the credibility of her delayed testimony despite minor inconsistencies.
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Case Digest (G.R. No. 86364)

Facts:

  • The case involves People of the Philippines vs. Lope Andaya, G.R. No. 86364, decided on May 6, 1991.
  • Lope Andaya was convicted of raping 14-year-old Irene Pilapil.
  • On February 19, 1987, Irene and her sister were sent to Andaya's workplace to collect money for household expenses.
  • Instead of returning home, Andaya invited the girls to stay overnight.
  • Irene testified that she was awakened to find Andaya removing her clothing and attempting to rape her.
  • She was unable to shout due to Andaya covering her mouth and threatening her with a knife.
  • Irene claimed she was raped three more times during the week they stayed with Andaya.
  • Five months later, she disclosed the assaults to her grandmother, who reported it to the authorities.
  • A medical examination on July 27, 1987, revealed a lacerated hymen that had healed.
  • Andaya denied the allegations, claiming the complaint stemmed from a confrontation with Irene's mother.
  • The trial court found the prosecution's evidence credible, convicting Andaya and sentencing him to reclusion perpetua, along with a P30,000 indemnity to the victim.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the trial court's decision, ruling that the prosecution's evidence was sufficient to establish Andaya's guilt beyond a reasonable doubt.
  • The Court found I...(Unlock)

Ratio:

  • The Supreme Court highlighted the significance of the trial court's factual findings, especially in rape cases where witness credibility is crucial.
  • Despite minor inconsistencies, Irene's testimony provided a coherent account of the events on February 19, 1987.
  • The Court acknowledged the societal stigma faced by rape victims, which often discourages them from reporting incidents, making it reasonable to believe that a victim would not fabricate such serious cl...continue reading

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