Title
People vs. Dizon
Case
G.R. No. 134802
Decision Date
Oct 26, 2001
A 21-year-old student was robbed, abducted, and raped by Renato Dizon, who threatened her with a knife. She escaped, identified him, and he was convicted of Robbery with Rape, with the death penalty upheld due to aggravating circumstances.

Case Digest (G.R. No. 134802)

Facts:

  • Incident and Commission of the Offense
    • On July 7, 1997, at approximately 9:30 p.m., private complainant Arlie Rosalin, a 21‑year‑old engineering student from Dinalupihan, Bataan, alighted from a bus along EDSA near Roosevelt Avenue in Quezon City.
    • Almost immediately after alighting, she was accosted by the appellant Renato Dizon y Zuela, who called out to her and suddenly seized her while pointing a fan knife at the side of her neck, announcing a holdup.
    • Under duress, she was compelled to face the railing of the bridge and surrender her wallet, jewelry, and later her backpack. The appellant threatened her that if he discovered any additional valuables, he would kill her and throw her over the bridge.
    • After removing her valuables, the appellant forced the complainant to walk with him along EDSA, disguising their passage as if they were a couple; this movement took them past major landmarks such as Roosevelt Avenue, Munoz market, and into Project 7.
    • Throughout the ordeal, the complainant was restrained and intimidated by the appellant, who had one hand holding her and the other brandishing his fan knife.
    • Upon reaching a dark, isolated basketball court, the appellant escalated the crime by ordering the complainant to remove her pants and underwear, subsequently subjecting her to a series of sexual abuses—including kissing, biting, and forceful vaginal penetration—despite her desperate attempts to comply minimally.
    • The appellant further demeaned the complainant by forcing her to massage his penis, claim his sexually transmitted “bolitas” on his organ, and compel her to perform oral sex using his foul-smelling organ.
    • When the complainant finally struggled and broke free after suffering multiple physical abuses, she managed to escape by running to a nearby store and seeking help, though assistance came only after a barangay officer intervened and accompanied her back to the scene where some of the appellant’s personal effects were recovered.
  • Arrest, Identification, and Procedural History
    • Soon after the incident, the complainant provided a description of the assailant, noting distinctive features such as a mole on the cheek and a body marked with tattoos from the waist down.
    • Based on this description, police and barangay officials identified a suspect matching the appellant’s description near the Munoz market as he was working as a tricycle dispatcher.
    • During confrontation, the appellant again brandished the same fan knife; however, he was disarmed by police officers, arrested, and later made to appear at the police station where his statement was recorded.
    • The case was formally charged in an Information dated July 14, 1997, charging him with robbery with rape under paragraph one, Article 294 of the Revised Penal Code, as amended by Republic Act No. 7659.
  • Trial and Testimony
    • At trial, the prosecution presented multiple witnesses including the complainant herself, a police officer, an investigating officer, and a medico‑legal officer.
    • The complainant’s testimony provided a detailed, step‑by‑step account of the robbery and the subsequent sexual violence and humiliation she suffered.
    • Cross‑examinations focused on verifying the complainant’s ability to identify the appellant despite the chaotic and intimidating circumstances.
    • The appellant, represented by counsel, maintained a defense based on denial and alibi—asserting he was at home or at his workplace, and therefore not present at the scene—and his testimony was not corroborated by any independent evidence or testimony.
  • Verdict and Penalties Imposed by the Trial Court
    • On July 13, 1998, the Regional Trial Court of Quezon City, Branch 219, found the appellant guilty beyond reasonable doubt of robbery with rape attended by two aggravating circumstances (cruelty and uninhabited place).
    • The trial court imposed the penalty of death upon the appellant and ordered him to pay:
      • P9,500.00 as actual damages (for stolen items)
      • P200,000.00 as moral damages for the physical and emotional trauma inflicted
      • Additionally, civil indemnity of P50,000.00 and exemplary damages of P25,000.00 were awarded.
    • The decision was transmitted for automatic review by the Supreme Court.
  • Appellant’s Grounds for Appeal
    • The appellant objected on the basis that he was not positively identified by the complainant.
    • He argued that the complainant’s account contained inconsistencies, particularly regarding her inability to escape despite opportunities, and questioned the plausibility of his use of both hands to commit the acts described.
    • The appellant also challenged the characterization and appreciation of the aggravating circumstances, specifically cruelty and the notion of the crime being committed in an uninhabited place, as well as a typographical error in the charge (paragraph one vs. paragraph two of Article 294).

Issues:

  • Credibility of the Complainant’s Testimony
    • Whether the complainant’s detailed identification of the appellant can be accepted as credible given the inherently traumatic circumstances in which the events unfolded.
    • Whether inconsistencies in the complainant’s narrative, as alleged by the appellant, are sufficient to undermine her testimony.
  • Validity of the Defense Raised by the Appellant
    • The sufficiency of the denial and alibi presented by the appellant, particularly in light of the clear and direct evidence provided by the complainant.
    • Whether the defense of alibi can overcome the complainant’s positive identification without any corroborative evidence supporting the appellant’s version of events.
  • Proper Appreciation of Aggravating Circumstances
    • Whether the trial court correctly applied the aggravating circumstances of cruelty and the selection of an uninhabited place in the commission of the crime.
    • The propriety of the trial court’s determination that the venue (a dark, isolated basketball court) justified the uninhabited place aggravation, despite nearby structures.
  • Correct Characterization of the Offense Under the Revised Penal Code
    • Whether the appellant’s conviction under paragraph one of Article 294 (as amended by R.A. 7659) was factually and legally correct, as opposed to the appellant’s contention regarding a misstatement (paragraph two).

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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