Facts:
People of the Philippines v. Edgardo Grefaldia, G.R. No. 121637, April 30, 2003, Supreme Court Second Division, Callejo, Sr., J., writing for the Court.Appellant Edgardo Grefaldia was charged in the Regional Trial Court (RTC) of Gumaca, Quezon, Branch 61, in Criminal Case No. 3199-G, with five counts of rape arising from events of December 3, 1988; three other perpetrators were charged as John Does and remained at large. The information alleged that Grefaldia, conspiring with three others and armed with an armalite rifle, used force, threats and intimidation to have carnal knowledge of the victim, Vilma Convocar, on multiple occasions that night.
At arraignment on September 27, 1989, Grefaldia pleaded not guilty and trial ensued. The prosecution presented the testimony of Vilma and the medical examination of Dr. Rosalia Villasanta, who examined Vilma on December 6, 1988 and reported marked vulvar congestion and inflammation and a profuse whitish discharge consistent with forcible, repeated intercourse. Vilma testified in detail: she heard gunshots that night, was ordered out of her house by masked men, was taken to Grefaldia’s house in Barangay San Pablo where she was raped repeatedly (first by Grefaldia, then by three others, then again by Grefaldia), and later escaped after Grefaldia shot at her on a highway. She identified Grefaldia by facial features once he removed his mask and by the short pants he wore the following day when she caused his apprehension.
The defense offered an alibi: Grefaldia testified he was in Bicol (Barangay Bagalayan, Castillas, Sorsogon) on December 3, 1988 and was apprehended only on December 4; witnesses Alonzo Guerrero and Alejo Larce gave conflicting accounts as to the dates and times that would place Grefaldia elsewhere. The trial court found the prosecution evidence credible, convicted Grefaldia of five counts of rape and sentenced him to five terms of reclusion perpetua, ordering P30,000 indemnity to the victim; the cases against the John Does were archived.
Grefaldia appealed, principally contesting the victim’s identification and ...(Subscriber-Only)
Issues:
- Was the conviction of Edgardo Grefaldia for five counts of rape supported by proof beyond reasonable doubt, considering the victim’s identification, medical corroboration, alleged alibi and the claim of darkness and masked assailants?
- Should the trial court’s award of civil indemnity and damages to ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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