G.R. No. 51513 - People vs. Gorospe

On October 8, 1974, a verified complaint was filed in the Municipal Court of Pulilan, Bulacan by Anastacia de Jesus charging forcible abduction with rape.
The original accused were Gerardo Fajardo, Rufino Bulanadi, and Feliciano Gorospe; however, a subsequent amendment on October 25, 1974 dropped Fajardo and substituted Oscar Alvaran.
The incident was initially alleged to have occurred on September 30, 1974 but later amended to September 25, 1974, with the crime spanning from Plaridel, Bulacan, passing through Pulilan to Talavera, Nueva Ecija.
Municipal Judge Alfredo V. Granados conducted the preliminary investigation in two stages, set bail at PhP15,000.00 for Bulanadi and Gorospe, while Alvaran remained at large, and eventually elevated the case to the Court of First Instance (CFI) of Bulacan due to the accused’s absence in the second stage.

On March 19, 1975, Provincial Fiscal Pascual C. Kliatchko filed the information against Bulanadi and Gorospe (Criminal Case No. 1293-M), which was further amended on July 25, 1975 detailing the specific allegations, including conspiracy, use of force, and the commission of rape.
The trial commenced on October 15, 1975 before Judge Nelly L. Romero Valdellon; however, the accused were tried in absentia due to their non-appearance despite proper notification.
During the trial, after partial testimony by the complainant, Judge Valdellon was transferred to Metro Manila and replaced by Judge Fidel P. Purisima, who eventually inhibited himself in view of a familial connection with Judge Granados.
Consequently, Judge Jesus R. de Vega assumed the task of rendering the decision, pronouncing that each accused was responsible not only for his own act of rape but also for that of his co-accused, as the crime was committed in conspiracy.

Anastacia de Jesus, a 14-year-old student from Calumpit Institute, Bulacan, was abducted on the morning of September 25, 1974, while searching for a book near the Caltex Station in Plaridel, Bulacan.
The complainant explained that she was drugged—after a handkerchief was waved across her face by one of the accused—and was forcibly boarded into a motor vehicle progressing towards Talavera, Nueva Ecija.
She later regained consciousness in a nipa hut near an irrigation pump at Calipahan, where, along with other detainees, the accused (Gorospe and Bulanadi) took turns in sexually abusing her throughout a nine-day ordeal.
Significant corroborative details include the testimony of Gerardo Fajardo, who, despite being dropped from the complaint, testified to certain critical events such as the use of a motor vehicle, the location transitions, and his observation of the events leading to her abuse.
Medical examination findings, affidavits, and subsequent corroborative statements by witnesses and parties (including those from the police and municipal officials) established the timeline and nature of the defendants’ actions.

The appellants (accused) advanced an alternative narrative suggesting that the events occurred in Talavera and at a birthday party, portraying Anastacia de Jesus as a willing participant and even implying her involvement in irregular relationships.
This version detailed events on September 30, 1974, involving interactions at a party attended by known local officials, including descriptions of disputes over the phenomenon of the complainant’s presence and alleged promiscuity.
The defense further attempted to question the completeness of cross-examination against the key witness Gerardo Fajardo, noting that his testimony was not entirely concluded before his repeated absence from court.
The record, however, showed that Fajardo’s testimony was extensively probed and that his cross-examination, though interrupted by his absences, had already covered material points crucial to the prosecution’s case.

Whether the complaint should have been filed in Plaridel, Bulacan, or Talavera, Nueva Ecija, given that elements of the alleged offense occurred in multiple locations.
Whether the Court of First Instance of Bulacan had proper jurisdiction despite some elements of the offense occurring in Nueva Ecija, considering the doctrine on continuing offenses and essential ingredient territory.

Whether Judge Jesus R. de Vega had proper jurisdiction to dissolve the case after the inhibition of Judge Purisima and the purported re-raffling of the case from one branch of the CFI to another.

Whether the trial court erred in admitting the testimony of Gerardo Fajardo when his cross-examination was deemed incomplete due to his failure to appear on subsequent dates, and whether such limitation affected the defendants’ right to a full confrontation.

Whether the evidence, including the complainant’s testimony and corroboration through medical and witness records, was sufficient to convict the accused beyond reasonable doubt.
Whether the alternative narrative presented by the appellants, which attempted to recast the complainant’s character and the dynamics of the incident, held any persuasive force in negating the established facts.