G.R. No. L-38179 - People vs. Arciaga

On or about September 5, 1968, Adoracion Hernandez, while riding her tricycle from her residence in Muntinlupa, Rizal towards the poblacion, was forcibly intercepted.
Witnesses testify that as the tricycle was driven by Buenaventura Tobias—with Armando Arciaga also present—accused Marcelino “Celing” Gonzales blocked the road, forcing the vehicle to stop.
Accused Adriano Arciaga, assisted by Celing Gonzales and Boy Rivera, forcibly seized the complainant from the tricycle.
The victim was dragged and loaded onto a waiting jeep driven by Boy Rivera, then taken first to Morong, Rizal, and later to Sta. Maria, Laguna.
In the account provided by the People, within the premises of Crispin Custodio’s house in Morong, and later at Ambrosio Magtipon’s house in Sta. Maria, the complainant was restrained, with details including:

Forced physical restraint (attempts to gag her with a handkerchief, being held down by accomplices).
Acts of sexual violence including explicit details of forceful (non-consensual) carnal intercourse despite her resistance, leaving physical injuries such as torn dress and bruises.

The incident is corroborated by other evidence, including the victim’s testimony and a signed letter to her parents, as well as physical evidence presented by the prosecution expert witness.

Accused-appellants present a radically different narrative claiming that Adriano Arciaga and Adoracion Hernandez were lovers planning an elopement to evade parental disapproval.
According to the defense:

The couple met in the early hours of September 5, 1968, with assistance from confidants (Celing Gonzales and Boy Rivera) who provided a vehicle for what was to be their secret journey.
They were accommodated initially by Crispin Custodio in Morong, Rizal, and later moved to a neighbor’s house (Fernando Austria) as the presence of curious onlookers grew evident.
Throughout their stay, the couple engaged in consensual sexual relations, lived together in a normal, almost marital, manner and even participated in ordinary social activities (e.g., using a local barber shop).

The defense underscores that during the alleged period of “captivity,” there were ample opportunities to call attention to their situation; the environmental and architectural setup of the houses (lack of locked windows and shutters) would have allowed for escape or intervention, implying voluntariness in the complainant’s actions.

While Boy Rivera and Marcelino Gonzales remained at large at the time of judgment (with Ambrosio Magtipon briefly apprehended), only Adriano Arciaga and Crispin Custodio were tried and convicted initially.
The sentencing differed markedly:

Adriano Arciaga was sentenced to death plus indemnity to the complainant.
Crispin Custodio received an indeterminate penalty as an accomplice, along with a subsidiary indemnity obligation.

Contradictory witness testimonies and discrepancies in physical evidence (e.g., injuries, condition of the victim’s dress) contributed to the complexity of the factual matrix of the case.

Whether the trial court erred in evaluating the credibility and reliability of the prosecution witnesses, given the substantial discrepancies among their accounts.
Whether the evidence adduced by the prosecution, including physical injuries and witness testimonies, was clear and conclusive enough to prove the commission of forcible abduction and rape beyond reasonable doubt.
Whether the court improperly gave weight to the alleged flight of co-accused and to the accused-appellants’ silence, thereby prejudicing their right to due process.
Whether the imposition of the supreme penalty on Adriano Arciaga was warranted despite arguments presented in favor of a lighter sentence or even acquittal based on the insufficiency of the evidence.
Whether the trial court misinterpreted or undervalued the defense evidence—particularly the alternative narrative of consensual elopement—and thus violated the constitutional presumption of innocence.