Title
People vs. Gahi
Case
G.R. No. 202976
Decision Date
Feb 19, 2014
Mervin Gahi convicted of raping his niece twice; Supreme Court upheld verdict, citing credible victim testimony, rejecting alibi and sweetheart defense. Penalties adjusted.

Case Digest (G.R. No. 202976)

Facts:

This is People of the Philippines v. Mervin Gahi, G.R. No. 202976, February 19, 2014, First Division, Leonardo‑De Castro, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the accused-appellant is Mervin Gahi.

On October 9, 2002 two Informations were filed each charging Mervin Gahi with one count of rape under Article 266‑A of the Revised Penal Code for incidents alleged to have occurred on March 11 and March 12, 2002 in Capoocan, Leyte. At arraignment on November 4, 2002, appellant pleaded not guilty. The prosecution presented as its principal witness the sixteen‑year‑old complainant (identified in the record by the initials AAA), who testified that appellant, who was married to her aunt, raped her on both dates by threatening her with a knife and forcing intercourse; she said he warned her not to tell anyone. The prosecution also offered a medical certificate by Dr. Bibiana Cardente noting pregnancy findings and testimony from a DSWD social worker documenting the victim’s admission and circumstances.

The defense presented AAA’s 74‑year‑old grandmother BBB, who denied seeing appellant on the relevant dates and said AAA never complained; Filomeno Suson and other witnesses gave testimony that appellant spent the days at issue working at a nearby copra kiln (an alibi); and Jackie Gucela testified that he was AAA’s boyfriend and the father of her child. Appellant also testified denying the rapes and asserting he was at the copra dryer with family.

The Regional Trial Court (Branch 13, Carigara, Leyte) rendered a Decision dated April 22, 2005 finding appellant guilty of two counts of rape and sentenced him to death for each count and ordered civil indemnity and exemplary damages. The Court of Appeals, in a Decision dated August 31, 2011 (CA‑G.R. CEB‑CR. H.C. No. 00335), affirmed the conviction but modified the penalty to reclusion perpetua for each count and awarded moral damages of Php50,000. Appellant appealed to the Supreme C...(Subscriber-Only)

Issues:

  • Did the prosecution prove appellant Mervin Gahi’s guilt for two counts of rape beyond reasonable doubt?
  • If guilty, what are the proper penalties and damages to be ...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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