Case Digest (G.R. No. 127750-52)
Facts:
People of the Philippines v. Crisanto Digma y Ubay, G.R. Nos. 127750-52, November 20, 2000, the Supreme Court En Banc, Bellosillo, J., writing for the Court. The accused-appellant is Crisanto Digma y Ubay; the complainant and offended party is Adora Balce; the prosecution is People of the Philippines.Accused was charged in three separate Informations with three counts of rape allegedly committed on 1 March, 24 October and 27 November 1994 against his fourteen-year-old sister‑in‑law Adora. The cases were tried before the Regional Trial Court (RTC), Branch 41, Daet, Camarines Norte. The RTC, in a decision dated 23 October 1996 (penal cases docketed Crim. Nos. 8398–8400), convicted Crisanto as charged and sentenced him to three death penalties, and awarded P50,000 moral damages and P20,000 exemplary damages per count (total P210,000). The RTC found the victim credible and rejected the accused’s claim that the sexual acts were consensual.
Facts adduced at trial: Adora testified in detail to sexual assaults by Crisanto on the three specified dates, describing physical restraint, threats to kill her family, removal of clothing and penile-vaginal penetration. She said she refrained from reporting earlier because of fear engendered by the threats. Medical examination showed hymenal lacerations and a vagina admitting one finger. Crisanto testified that the sexual relations were consensual and asserted a prior amorous relationship; he offered a purported “love letter” and his own account of repeated consensual encounters, including dog‑style and standing positions. Adora denied authorship of the letter and produced handwriting samples.
On appeal, the principal factual dispute was credibility—whether the acts were forcible rape or consensual intercourse. The Court of Appeals’ disposition is not separately reported in the rollo excerpt; the case reached the Supreme Court by petitio...(Subscriber-Only)
Issues:
- Was the conviction for rape proper, i.e., did the evidence prove that rape was committed and that the complainant did not consent?
- Whether the qualifying circumstance (victim under 18 and offender a relative by affinity within the third civil degree) was sufficiently proved to sustain the imposition of the death penalty.
- Whether the awards of civil indemnity, moral and exemplary damage...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
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