Case Digest (G.R. No. 102077)
Facts:
In the case of The People of the Philippines vs. Norberto Errojo, G.R. No. 102077, decided on January 4, 1994, the accused-appellant, Norberto Errojo, was charged with two counts of rape against complainant Anita Q. Arabia, who was fourteen years and eight months old at the time of the incidents. The alleged crimes took place on March 5 and March 12, 1989, in Barangay Cudian, Ivisan, Capiz. The information filed on January 30, 1990, stated that Errojo, armed with a knife and using violence and intimidation, engaged in carnal knowledge with Arabia against her will, resulting in her pregnancy.
At his arraignment, Errojo, represented by counsel, pleaded not guilty. On June 28, 1991, the Regional Trial Court of Roxas City, Branch 15, found Errojo guilty beyond reasonable doubt, sentencing him to reclusion perpetua for each count of rape and requiring him to indemnify Arabia. The prosecution's case was built upon Arabia's detailed account of the attacks while corroborated by
Case Digest (G.R. No. 102077)
Facts:
# Incident Details
- First Rape (March 5, 1989):
- Complainant Anita Q. Arabia, aged 14, was walking home alone in Barangay Cudian, Ivisan, Capiz, at around 6:00 p.m.
- Accused Norberto Errojo, armed with a knife, collared her from behind, pushed her into a forested area, and threatened her.
- He removed her shorts and underwear, forced her to the ground, and raped her twice. Afterward, he threatened to kill her and her brothers if she reported the incident.
- Complainant noticed blood on her underwear but did not report the incident to her parents, fearing the accused's threats.
- Second Rape (March 12, 1989):
- One week later, the accused again accosted complainant while she was returning home after doing laundry.
- He raped her twice at knifepoint and repeated his threats to kill her and her brothers if she reported the incident.
# Discovery of Pregnancy
- Complainant kept the incidents secret until November 16, 1989, when she underwent a medical examination for a Citizen's Military Training (CMT) requirement.
- The physician discovered she was eight months pregnant. She then revealed the rapes to her mother.
- On December 11, 1989, she gave birth to a boy, Amer John Arabia, and discontinued her studies to care for him.
# Accused’s Defense
- The accused, Norberto Errojo, denied the charges, claiming he had moved to Barangay Cabugao in August 1988 due to quarrels with complainant’s family.
- He presented an alibi, stating he was working on a fishpond on March 5, 1989, and fetching water on March 12, 1989.
- He insinuated that complainant’s family had a grudge against him and that the charges were fabricated.
# Trial Court Decision
- The trial court found the accused guilty beyond reasonable doubt of two counts of rape and sentenced him to reclusion perpetua for each count, with indemnification of P40,000 for each offense.
- The court also ordered the cancellation of the accused’s bail bond.
Issues:
- Whether the accused, Norberto Errojo, is guilty beyond reasonable doubt of the two counts of rape.
- Whether the complainant’s delay in reporting the rapes and her failure to resist the accused’s advances affect her credibility.
- Whether the accused’s alibi and claim of a family grudge are sufficient to overturn the conviction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
- Complainant Anita Q. Arabia, aged 14, was walking home alone in Barangay Cudian, Ivisan, Capiz, at around 6:00 p.m.
- Accused Norberto Errojo, armed with a knife, collared her from behind, pushed her into a forested area, and threatened her.
- He removed her shorts and underwear, forced her to the ground, and raped her twice. Afterward, he threatened to kill her and her brothers if she reported the incident.
- Complainant noticed blood on her underwear but did not report the incident to her parents, fearing the accused's threats.
- One week later, the accused again accosted complainant while she was returning home after doing laundry.
- He raped her twice at knifepoint and repeated his threats to kill her and her brothers if she reported the incident.
- Complainant kept the incidents secret until November 16, 1989, when she underwent a medical examination for a Citizen's Military Training (CMT) requirement.
- The physician discovered she was eight months pregnant. She then revealed the rapes to her mother.
- On December 11, 1989, she gave birth to a boy, Amer John Arabia, and discontinued her studies to care for him.
# Accused’s Defense
- The accused, Norberto Errojo, denied the charges, claiming he had moved to Barangay Cabugao in August 1988 due to quarrels with complainant’s family.
- He presented an alibi, stating he was working on a fishpond on March 5, 1989, and fetching water on March 12, 1989.
- He insinuated that complainant’s family had a grudge against him and that the charges were fabricated.
# Trial Court Decision
- The trial court found the accused guilty beyond reasonable doubt of two counts of rape and sentenced him to reclusion perpetua for each count, with indemnification of P40,000 for each offense.
- The court also ordered the cancellation of the accused’s bail bond.
Issues:
- Whether the accused, Norberto Errojo, is guilty beyond reasonable doubt of the two counts of rape.
- Whether the complainant’s delay in reporting the rapes and her failure to resist the accused’s advances affect her credibility.
- Whether the accused’s alibi and claim of a family grudge are sufficient to overturn the conviction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
- The trial court found the accused guilty beyond reasonable doubt of two counts of rape and sentenced him to reclusion perpetua for each count, with indemnification of P40,000 for each offense.
- The court also ordered the cancellation of the accused’s bail bond.
Issues:
- Whether the accused, Norberto Errojo, is guilty beyond reasonable doubt of the two counts of rape.
- Whether the complainant’s delay in reporting the rapes and her failure to resist the accused’s advances affect her credibility.
- Whether the accused’s alibi and claim of a family grudge are sufficient to overturn the conviction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)