G.R. No. 141949 - Padua vs. Ranada

The appellant, Michael Espera y Cuyacot, was charged in Criminal Cases Nos. 99-511 and 99-512 for the crimes of rape by sexual assault and rape by sexual intercourse committed against the victim, identified as Ana.
The offenses were charged under Article 266-A, paragraph 2 (rape by sexual assault) and Article 266-A, paragraph 1(a) (rape by sexual intercourse) in relation to Article 266-B of R.A. No. 8353, along with reference to R.A. No. 7659 in one of the cases.

At approximately 11:30 p.m. in Ubay, Bohol, victim Ana and her co-worker Susie hailed a tricycle driven by the appellant to share a ride, under a well-lit environment with streetlights, nearby chapel lights, and illuminated houses.
Although Ana recognized the driver’s face as he was wearing a red polo shirt and denim (or maong) pants, she did not know his name. Susie, using her flashlight, helped confirm his identity.

Upon reaching Barangay Ekis, Susie disembarked first while Ana remained in the tricycle and requested to stop near her residence.
The driver, claiming that the tricycle’s brakes were not working and later that it had run out of gas, instead stopped at a quarry site, placing Ana in a vulnerable situation.

As Ana walked home under a bright moonlight, she heard rustling and turned to find the appellant following her; he appeared naked from the waist up with his red polo shirt now covering his face and held a gun.
The appellant chased Ana, caught her, covered her mouth, and threatened her with the gun. He then:

Punched her in the upper stomach, causing her to lose balance and fall.
Dragged her by the hair to a secluded location.
Pushed her to the ground, repeatedly punched her, and forcibly undressed her.
Committed rape by sexual assault by forcing his penis into her mouth despite her refusal.
Further raped her by sexual intercourse by forcefully penetrating her despite her protests, which resulted in severe physical injuries.

Following the assault, the appellant repeatedly threatened Ana, ordering her to blindfold herself with her own shirt and remain seated until he departed.
The next day, Ana reported the incident to her mother and later to the authorities, resulting in her subsequent medical examination that revealed multiple contusions, lacerations, abrasions, bite marks, and evidence of rape.
The victim positively identified the appellant during the police investigation, despite the latter having altered his appearance by cutting his hair and shaving his beard.
The appellant’s subsequent flight from Ubay, Bohol, and his eventual apprehension in Pampanga further factored in establishing his guilt.

At arraignment, the appellant pleaded not guilty to both charges and asserted multiple defenses, including:

Doubt over the identification of the assailant.
Claims that the prosecution failed to prove he was driving the tricycle at the critical time.
Alleging that the darkness impaired the victim’s ability to properly identify him.
Questioning the victim’s conduct before, during, and after the incident.

Pre-trial and trial proceedings were conducted where both the testimonies of the victim and the medical examination results played crucial roles.

The Regional Trial Court (RTC) found the appellant guilty beyond reasonable doubt for both crimes.
The RTC imposed an indeterminate sentence ranging from 4 years and 2 months (prision correccional) to 14 years, 8 months, and 1 day (reclusion temporal) for rape by sexual assault, and reclusion perpetua for rape by sexual intercourse.
Additional orders included the payment of civil indemnity, moral damages, and exemplary damages to the victim in both cases.

Whether the prosecution established beyond reasonable doubt that the appellant was indeed the tricycle driver observed by the victims.
Whether the victim’s identification of the appellant, based on visual and auditory recognition under the conditions described, was reliable and credible.

Whether the medical findings corroborated the victim’s testimony regarding the multiple injuries sustained during the assault.
Whether the elements constituting both rape by sexual assault and rape by sexual intercourse were sufficiently proven by the prosecution.

Whether the appellant’s defense, particularly his claims regarding his alibi and the alleged inability of the victim to identify him due to darkness and her behavior during the incident, held merit.
Whether any inconsistencies in the appellant’s version of events negated the prosecution’s case.

Whether the damages awarded by the trial court, along with the modified civil liabilities imposed by the Court of Appeals, were appropriate as to the gravity of the crimes.
Whether the imposition of legal interest on the awarded damages was just and in conformity with prevailing jurisprudence.