Title
People vs. Joel Gabisay, Jr. and Ronnie Doninia
Case
G.R. No. 256301
Decision Date
Mar 1, 2023
The Supreme Court affirmed the conviction of accused for forcible abduction with rape and rape, imposed reclusion perpetua without parole, and awarded damages with interest to the victim.
A

Case Digest (G.R. No. 252199)

Facts:

  • Charges and Indictment
    • Joel Gabisay, Jr. and Ronnie Doninia were charged by Information for forcible abduction with rape.
    • The incident allegedly occurred on or about May 3, 2007, in a place within the jurisdiction of the court.
    • The accused, armed with a gun and while on board a motorized tricycle, forcibly abducted a 17-year-old minor female victim (AAA256301).
    • The victim was taken against her will, without consent, to a secluded location.
    • Both accused men allegedly took turns in having carnal knowledge of the victim by using force and intimidation.
  • Testimony of the Victim (AAA256301)
    • On May 3, 2007, at around 9:30 p.m., the victim was at a waiting shed with her boyfriend when two men on a motorcycle stopped in front of them.
    • Ronnie Doninia (passenger) brandished a gun and threatened the victim and her boyfriend, demanding bags and money.
    • After the victim refused, Doninia forcibly pulled her to board the motorcycle with Joel Gabisay (driver).
    • They proceeded to a vacant, secluded lot far from houses, where Doninia blindfolded the victim and took her a few meters away from the motorcycle.
    • Doninia claimed they were police officers working on the mayor's instructions.
    • Despite being ordered to undress and threatened, the victim refused to shout and was coerced to touch the gun.
    • Doninia forcibly fondled and then raped her for about five minutes.
    • Afterwards, Gabisay was called by Doninia and also proceeded to forcibly have sexual intercourse with the victim for about three minutes.
    • After the assaults, Doninia threatened the victim not to tell anyone and asked her to be his girlfriend.
    • The victim was then dropped off at a street corner and instructed to take a jeepney home.
    • She reached home around 11:00 p.m., confided to her parents but asked them to keep the matter private due to embarrassment.
  • Identification and Complaints
    • The victim identified Joel Gabisay at the barangay hall after being urged by her cousin to confirm the identity of a man accused of lascivious acts.
    • Complaints were subsequently filed against both Joel Gabisay and Ronnie Doninia, after AAA256301 identified Doninia through a photograph.
  • Medical Examination
    • Dr. Jesille C. Baluyot examined the victim on June 1, 2007.
    • The medico-legal report showed deep healed lacerations on the victim's hymen, diagnostic of previous blunt force or penetrating trauma.
    • There were no signs of complications from penetrating trauma.
  • Defense Statements
    • Gabisay claimed he was at work in a slaughterhouse at the time of the incident.
    • Doninia stated he was at home with his pregnant wife.
    • Doninia further alleged that he was implicated because Gabisay was maltreated by police and forced to name him.
  • Trial and Lower Courts' Decisions
    • The Regional Trial Court (RTC) found both accused guilty beyond reasonable doubt, sentenced them to reclusion perpetua without parole, and awarded damages to the victim.
    • The RTC considered the victim's testimony credible and ruled physical impossibility of their presence at the crime scene was not a valid defense.
    • The Court of Appeals (CA) denied the appeal, affirming conviction and increasing monetary damages.
    • The CA noted the reliability of the out-of-court identification and consistency of the victim's testimony despite delay in reporting.

Issues:

  • Whether Joel Gabisay, Jr. and Ronnie Doninia were proven guilty beyond reasonable doubt of forcible abduction with rape.
  • Whether the conviction and penalties imposed by the RTC and affirmed by the CA were proper, considering the facts and evidences.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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