Case Digest (G.R. No. 126817)
Facts:
People of the Philippines v. Guilbert Arcillas y Perez, G.R. No. 126817, December 27, 2000, the Supreme Court Second Division, Quisumbing, J., writing for the Court.On the morning of August 18, 1995, private complainant Isabel Lanipa y Perez and her husband travelled from Tagasilay, Zamboanga City to their farm in Simanta; her husband stopped to talk with a relative and Isabel proceeded alone. At the farm she found her nephew, Guilbert Arcillas y Perez (the accused), seated beside the nipa hut with his pants down; he left and then returned carrying a heavy round wooden stick. While Isabel was at the creek washing clothes she felt someone behind her and was struck on the right eyebrow by the stick, losing consciousness. When she regained consciousness she was bleeding and later dragged herself to the nipa hut to await her husband.
Her husband brought her first to Quiniput Emergency Hospital and then to Zamboanga Regional Hospital for further examination because he suspected sexual assault; laboratory examination showed the presence of sperm cells in Isabel’s genital specimen. On August 23, 1993, a complaint was filed charging Guilbert with rape with frustrated homicide; an arrest warrant issued that same day. The accused was arraigned on September 17, 1993 and pleaded not guilty; a court social worker’s report showed Guilbert was a minor at the time of the incident.
At trial Guilbert admitted hitting his aunt with the wooden stick out of anger but neither admitted nor denied raping her. The trial court found him guilty beyond reasonable doubt of rape with frustrated homicide and sentenced him to reclusion perpetua, ordered indemnity and reimbursement, but, noting his minority, suspended further proceedings and committed him to the Department of Social Services and Development pursuant to the court’s discretion. Guilbert appealed to the Court of Appeals and thereafter to the Supreme Court via a direct appeal (appeal from the trial court judgment).
Before the Court the accused challenged only the sufficiency of evidence to sustain conviction for rape with frustrated homicide; the Solicitor General...(Subscriber-Only)
Issues:
- Was there sufficient proof beyond reasonable doubt to convict appellant Guilbert Arcillas y Perez of rape?
- If not guilty of rape, was appellant nonetheless guilty of frustrated homicide, and what penalty and damages ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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