Case Digest (G.R. No. 191390)
Facts:
The People of the Philippines v. Joel Dioquino y Garbin, G.R. No. 191390, April 02, 2014, the Supreme Court First Division, Villarama, Jr., J., writing for the Court.The respondent-appellant, Joel Dioquino, was charged in two informations with rape of seventeen-year-old minor ABC: Criminal Case No. 1390 (an incident alleged on or about July 31, 1999) and Criminal Case No. 1391 (alleging seven successive rapes from August 1 to August 16, 1999). Upon arraignment appellant pleaded not guilty and trial on the merits followed.
The prosecution presented ABC’s detailed account of repeated assaults occurring at various locations in Barangay Gadgaron, Matnog, Sorsogon from July 31 to August 16, 1999, and the medical testimony of Municipal Health Officer Rosanna B. Galeria describing abrasions, hematomas, and hymenal lacerations consistent with penetration. The defense advanced a “sweetheart” or consensual relationship theory: appellant testified he was ABC’s boyfriend and that they had consensual sexual relations and had eloped; a handwritten statement prepared by the barangay captain (appellant’s uncle) and ABC’s affirmative reply at a police inquiry were relied upon by defense to show voluntariness.
The Regional Trial Court (RTC), Branch 55, Irosin, Sorsogon, convicted appellant of seven counts of simple rape in Criminal Case Nos. 1390–1391 (Decision dated June 18, 2007), sentenced him to reclusion perpetua for each count, and awarded P50,000 civil indemnity and P50,000 moral damages. The Court of Appeals (CA), in CA-G.R. CR-H.C. No. 02990 (Decision dated October 15, 2009, penned by Associate Justice Rebecca De Guia-Salvador), affirmed the conviction but modified the damages to P50,000 civil indemnity and P50,000 moral damages for each count.
Appellant appealed to the Supreme Court, which considered whether ABC’s testimony was credible and w...(Subscriber-Only)
Issues:
- Was the victim ABC’s testimony credible such that the RTC and CA properly convicted appellant of seven counts of rap...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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