Case Digest (G.R. No. 218245) Core Legal Reasoning Model
Facts:
In the case People of the Philippines vs. Jesus Empuesto y Socatre, G.R. No. 218245, decided on January 17, 2018, the accused-appellant Jesus Empuesto y Socatre was charged with rape under Article 266-A(1)(a) of the Revised Penal Code, as amended by Republic Act No. 8353. The incident occurred on or about July 3, 2005, in the Municipality of xxxxxxxxxxx, Province of Bohol. The private complainant, identified by the initials AAA to protect her identity, testified that at about 1:00 a.m., the accused stealthily entered her house through a hole in the bamboo floor while armed with a bolo. He threatened her and her children with death if she made any noise. The accused forced AAA to remove her panty and raped her while she was breastfeeding her youngest child. BBB, her eight-year-old daughter, overheard the incident but did not intervene due to fear. AAA reported the incident to her parents-in-law and subsequently to the police, and she underwent a medico-legal examination by Dr. J
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Case Digest (G.R. No. 218245) Expanded Legal Reasoning Model
Facts:
- Charge and Criminal Information
- Accused-appellant Jesus Empuesto y Socatre (Empuesto) was charged with rape under Article 266-A(1)(a) of the Revised Penal Code, as amended, for an incident occurring on or about July 3, 2005, in xxxxxxxxxxx, Bohol.
- The Information alleged that Empuesto, with carnal lecherous intent, used force, threat, and intimidation to have carnal knowledge of the victim AAA against her will and consent.
- Upon arraignment, Empuesto pleaded not guilty.
- Testimonies and Incident Description (Prosecution's Version)
- On July 1, 2005, Empuesto invited Rebecca Bantilan's husband to a PTA meeting; because the husband was plowing the field, Rebecca went with Empuesto.
- Around 2:30 p.m., while at AAA’s house, Empuesto peeped inside and inquired about AAA’s husband’s whereabouts, calling AAA "Marehan" due to a family connection.
- On July 3, 2005 at about 1:00 a.m., Empuesto entered AAA's house stealthily through a hole in the bamboo slat floor while AAA and her four children were sleeping inside a mosquito net with the light on.
- Empuesto was armed with a bolo, switched off the light, threatened AAA and her children not to make noise, and told AAA he needed only her.
- Despite AAA’s inability to move due to fear, Empuesto forced her to remove her panty and had carnal knowledge of her while she was breastfeeding her crying youngest child.
- After the incident, Empuesto left through the hole in the floor. AAA and her daughter BBB found a black panty on the floor believed to belong to Empuesto and a bolo that belonged to the family.
- That morning, AAA reported to her parents-in-law and police and underwent medico-legal examination by Dr. Jaime Gregorio L. Salarda, who found fresh lacerations consistent with rape.
- The incident caused AAA to incur expenses amounting to around P20,000 and caused her husband to lose his job.
- Defense Version
- Empuesto, his brother Basilio, and Sanie Bautista testified that on July 2, 2005, Empuesto attended a vigil at the plaza near the house of deceased barangay captain Pedro Bautista and stayed there until about 7:00 a.m. on July 3, accompanied by Basilio and Sanie.
- Basilio and Sanie supported that Empuesto was with them throughout the night of July 2 to July 3.
- Empuesto was arrested by police at around 8:00 a.m. on July 3 while on his way back to the vigil.
- Ruling of the Regional Trial Court (RTC)
- The RTC found AAA’s testimony straightforward and credible due to lack of motive to fabricate and corroboration from medical evidence and other witnesses.
- BBB’s testimony, though not identifying the intruder, did not weaken the prosecution’s case.
- Rebecca’s testimony suggested that Empuesto ensured AAA's husband was away before the incident.
- Empuesto’s alibi was weak as it was physically possible for him to be at AAA's house given its proximity to the vigil.
- The RTC found Empuesto guilty beyond reasonable doubt of rape and sentenced him to reclusion perpetua and ordered payment of P50,000 civil indemnity.
- Ruling of the Court of Appeals (CA)
- The CA affirmed the RTC decision, emphasizing the credibility of AAA’s testimony.
- Addressed issues on minor inconsistencies and AAA’s failure to shout for help, holding these did not destroy credibility.
- Awarded moral damages of P50,000 and exemplary damages of P30,000, with 6% interest on damages from finality until fully paid.
- Appeal to the Supreme Court
- Empuesto appealed, arguing failure of the prosecution to prove guilt beyond reasonable doubt and inconsistencies in AAA’s testimony.
- The Supreme Court reviewed the evidence and testimonies, including medical findings and demeanor of witnesses.
Issues:
- Whether the prosecution proved beyond reasonable doubt the guilt of accused-appellant Jesus Empuesto y Socatre for the crime of rape under Article 266-A(1)(a) of the Revised Penal Code, as amended.
- Whether the positive and categorical testimony of the victim is sufficient to establish the commission of rape despite alleged inconsistencies and the victim’s failure to shout for help.
- Whether the defense of denial and alibi presented by the accused-appellant was sufficiently established to acquit him.
- Whether the award of damages by the CA was appropriate and sufficient.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)