Case Digest (G.R. No. 242513)
Facts:
The case involved PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ARMANDO BUEZA Y RANAY, ACCUSED-APPELLANT; accused was charged with Robbery with Rape and with Grave Threats for incidents on August 31, 2013 (robbery and rape) and September 4, 2013 (threats) against AAA, then seventeen years old. He pleaded not guilty on October 1, 2013.The Regional Trial Court, Branch 172, Valenzuela City, convicted him on August 5, 2015; the Court of Appeals affirmed with modifications on May 31, 2017; accused appealed to the Supreme Court, which rendered judgment on November 18, 2020.
Issues:
- Was the accused guilty of Robbery with Rape?
- Was the accused guilty of Grave Threats?
Ruling:
The appeal was dismissed and the Court affirmed the Court of Appeals' decision with modification. The Court found ARMANDO BUEZA Y RANAY guilty of Robbery with Rape under Article 294 of the Revised Penal Code and of Grave Threats under Article 282 of the Revised Penal Code, deleted t Case Digest (G.R. No. 242513)
Facts:
- Parties and charges
- PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE charged ARMANDO BUEZA Y RANAY, ACCUSED-APPELLANT in Criminal Case No. 1224-V-13 with Robbery with Rape in relation to Republic Act No. 7610 and in Criminal Case No. 1225-V-13 with Grave Threats in relation to Republic Act No. 7610.
- Criminal Case No. 1224-V-13 alleged that on or about August 31, 2013, in xxxxxxxxxxx, the accused, by means of violence and intimidation upon victim AAA, then seventeen years old (DOB: November 28, 1995), forcibly took two cellular phones (valued P1,700.00 and P1,000.00) and a wallet containing P4,000.00, and by reason and on the occasion thereof, with lewd design and at knifepoint, had sexual intercourse with her against her will.
- Criminal Case No. 1225-V-13 alleged that on or about September 4, 2013, in xxxxxxxxxxx, the accused willfully and unlawfully threatened the life of AAA by uttering: "HUMANDA KA SA SUSUNOD NATING PAGKIKITA, PAPATAYIN NA KITA."
- Factual narrative and evidence
- Prosecution version: on August 31, 2013 at about 11:30 p.m., AAA was accosted, forced to the ground, threatened with a knife, robbed of two cellphones and P4,000.00, marched past a crowded bridge, led into a public restroom, stripped, kissed on breast and vagina, and had the accused's penis inserted into her vagina; the accused warned her he would kill her if she left before he was gone.
- Victim first reported the robbery at the police station but withheld disclosure of rape out of embarrassment; on September 4, 2013 she encountered the accused near her workplace, later identified him to police, and the accused was arrested after police accompaniment.
- Medico-legal evidence: Police Chief Inspector Gracia Catherine C. Guno, M.D., in Medico-Legal Report No. R13-256N, found no evident external injuries and no hymenal laceration, but opined that absence of laceration did not preclude sexual abuse.
- Defense version: the accused denied knowledge of the victim, claimed employment as a barker at a tollgate on the dates alleged, denied the robberies and rape, and alleged that the victim was a prostitute who had a dispute with his friend.
- Procedural history and prior rulings
- Accused pleaded not guilty at arraignment on October 1, 2013.
- On August 5, 2015, the Regional Trial Court, Valenzuela City, Branch 172, found the accused guilty beyond reasonable doubt of Robbery with Rape and of Grave Threats and sentenced him to reclusion perpetua ...(Subscriber-Only)
Issues:
- Primary legal question
- Whether ARMANDO BUEZA Y RANAY is guilty beyond reasonable doubt of Robbery with Rape and of Grave Threats.
- Specific contentions raised by the accused-appellant
- The accused argued that material inconsistencies and contradictions in the prosecution evidence failed to definitively identify him as the assailant.
- The accused contended that the medico-legal examination showing no bodily injuries, no hymenal laceration, and no semen refuted the charge of Rape.
- The accused maintained that the presenc...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)