Case Digest (G.R. No. L-48010)
Facts:
The People of the Philippines v. Sancho Budol y Ayente and Wilfredo Llaguno y Bardiago, G.R. No. L-48010. July 31, 1986, Supreme Court First Division, Melencio‑Herrera, J., writing for the Court. The prosecution charged Sancho Budol (principal) and Wilfredo Llaguno (accomplice) with rape before the Municipal Court of Mangatarem; the case was thereafter prosecuted in the Court of First Instance of Pangasinan, Branch I, as Criminal Case No. L-1520-I. After arraignment both pleaded not guilty and trial followed. The complainant, Lyneath Poquiz, then 16, testified she was accosted while riding her bicycle on September 25, 1977, taken into the Mangatarem Elementary School grounds, pulled into the boys’ and then the girls’ toilet, and there forcibly raped by Budol while Llaguno stood guard; she identified torn clothing and recounted physical resistance and injuries.Medical examinations: the Municipal Health Officer observed Lyneath scared with torn clothing and a contusion; a subsequent exam at the Pangasinan Provincial Hospital produced a medico‑legal certificate noting abrasion of the labia minora and a fresh laceration of the hymen and that the vagina admitted two fingers with difficulty (Exhibit A), while vaginal smear for spermatozoa was negative. Lyneath’s parents found Budol in the act and Budol was detained until police arrived.
At trial Budol denied forcible rape and asserted a consensual love relationship with Lyneath, presenting love letters, a birthday card, and a photograph as proof; other defense witnesses suggested prior visits. Llaguno denied participation. On February 28, 1978, the trial court convicted Budol of consummated rape aggravated by nocturnity and isolated place and sentenced him to reclusion perpetua with indemnity and costs; Llaguno was found guilty as accomplice but, being seventeen, his sentence was suspended and he was committed to a training school. Llaguno later moved to withdraw his appeal with his father’s conformity; the Court granted the withdrawal and entered final judgment as to him.
Budol appealed to the Supreme Court raising multi...(Subscriber-Only)
Issues:
- Did the trial court err in crediting the complainant’s testimony and convicting Sancho Budol given the conflicting evidence and defenses attacking credibility?
- Were the essential elements of consummated rape (penetration and lack of consent) sufficiently established despite absence of spermatozoa and limited external injuries?
- Were nocturnity and isolated (uninhabited) place properly considered aggravating circumstances?
- Should the indemnity ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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