Case Digest (G.R. No. 237412)
Facts:
People of the Philippines v. Ernesto Atuel @ Loloy Bolhog, G.R. No. 106962, September 03, 1996, Supreme Court Third Division, Panganiban, J., writing for the Court.The People charged accused-appellant Ernesto Atuel with rape under Article 335 of the Revised Penal Code in a complaint filed by the victim's mother and approved by the City Prosecutor. Atuel pleaded not guilty at his arraignment before the Regional Trial Court of Davao City, Branch 11, and proceeded to trial. In a March 29, 1992 decision the trial court found Atuel guilty as charged and sentenced him to reclusion perpetua, ordered P40,000 civil indemnity, and imposed costs.
The prosecution's case relied primarily on the testimony of neighbor Severo Echavez, who said he was awakened at about 3:00 a.m. on August 23, 1991 by cries for help, went to investigate, and found the accused having sexual intercourse with a woman lying on a makeshift table; Echavez then reported the incident to the Sta. Ana Police Patrol Station. Police Officer Prospero Ondong, Sr. corroborated that he and a mobile patrol found the accused half-naked, moving in a push-and-pull motion over a woman who later said, “Gi-rape ko, Sir.” The victim, whose real name was shown to be Felicitas Sayon, was brought to the Davao Medical Center and later examined by the Davao City Health Office; medical findings included healing hymenal lacerations. Medical testimony and records established that Sayon suffered from a psychiatric disorder (schizophreniform disorder) and exhibited incoherence and abnormal behavior.
The defense presented the accused and his sister, Lydia Atuel, who claimed another man, Caloy Reynoso, was seen with the complainant at the scene and that Echavez had ill motive stemming from a prior quarrel. The accused claimed he was on a neighborhood ronda and was wro...(Subscriber-Only)
Issues:
- Did the trial court err in crediting the prosecution witnesses and in finding them credible?
- Was the accused proven guilty of rape beyond reasonable doubt under Article 335 of the Revised ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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