Title
Supreme Court
People vs. Empuesto y Socatre
Case
G.R. No. 218245
Decision Date
Jan 17, 2018
Accused-appellant convicted of raping AAA in Bohol, Philippines, using force and a bolo. Alibi defense rejected; Supreme Court upheld conviction, awarding damages with interest.

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)

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