Case Digest (G.R. No. 130601)
Facts:
People of the Philippines v. Rafael Diopita y Guzman, G.R. No. 130601, December 04, 2000, the Supreme Court Second Division, Bellosillo, J., writing for the Court.The prosecution (the People of the Philippines) charged Rafael Diopita y Guzman with robbery with rape for acts committed on the evening of 16 April 1995. The complaining witness, Dominga Pikit-pikit, testified that about 9:00 p.m. a man accosted her, threatened her with death, dragged her into a field, punched her, took her jewelry and P1,000.00 in cash, and thereafter forcibly removed her clothing and raped her. She testified she had a clear view of her attacker because the full moon illuminated his face; she also reported that the assailant placed the stolen items in his shorts pocket and then warned her not to tell anyone.
Police follow-up the next day led to recovery of a white/yellow slipper at the scene and to the rounding up of four men from nearby houses, including accused-appellant. At a police line-up early on 17 April 1995, Dominga identified Diopita as her assailant; the slipper fitted him. A medical examination showed she was “positive for spermatocytes.” Diopita was detained and charged.
At trial the defense asserted alibi: Diopita claimed he spent the evening in an informal Bible session with his wife, child and fellow Jehovah’s Witnesses at the house of Eulalio Nisnisan, reportedly 15–50 meters from the crime scene. His wife and fellow worshippers corroborated his presence and attested to his moral character. The trial court (Regional Trial Court, Branch 11, Davao City, presided by Judge Virginia Hofilena-Europa) rejected the alibi, credited Dominga’s positive identification and found Diopita guilty of robbery with rape, sentencing him to reclusion perpetua and ordering payment of actual damages (P8,500.00) and moral damages (P50,000.00). The trial court’s decision was rendered 18 June 1997.
Diopita appealed to the Supreme Court. Before the Court, he renewed his attacks on the sufficiency and credibility of the identification, the weight of the prosecution’s evidence, the supposed inconsistenci...(Pro-only)
Issues:
- Did the trial court err in rejecting accused-appellant Rafael Diopita’s defense of alibi?
- Did the prosecution prove beyond reasonable doubt that accused-appellant committed robbery with rape?
- Is civil indemnity mandatory upon conviction for rape in addition to actua...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)