Case Digest (G.R. No. 56768)
Facts:
People of the Philippines v. Pablo Lactao, G.R. No. 56768, October 29, 1993, First Division, Bellosillo, J., writing for the Court.The prosecution charged Pablo Lactao (accused-appellant) with rape with serious illegal detention based on the allegations of Apolonia Aramburo (complainant). Apolonia testified that on 15 April 1979 she was taken by Luz Lactao (the accused’s wife) from the vicinity of Teresita Alburo Perfecto’s house to the house of the accused in Sts. Peter & Paul Subdivision, where she was confined in a small 2 m. x 3 m. room for about two weeks and repeatedly raped each night while Luz purportedly watched and laughed. Apolonia also alleged prior instances when the accused had taken her to a camarin and raped her. Her half-sister, Avelina Cadag, reported Apolonia’s disappearance to the police and later saw her on 29 April 1979 when Apolonia escaped.
A medical examination by the Senior Resident Physician of Sorsogon Provincial Hospital found old healed lacerations of the hymen; the physician testified that such lacerations could be caused by various nonsexual acts and that the cause could not be definitely determined. The accused denied the charges, asserted that the rape accusation was fabricated to compel him to vacate tenancy over land owned by Apolonia’s family, and maintained it was improbable he would commit rape in the presence of his wife and five children. Luz Lactao likewise denied fetching Apolonia, saying she had recently delivered and was still recuperating.
On 9 December 1980 the Court of First Instance of Sorsogon, Tenth Judicial District (Branch I) found Apolonia’s testimony credible, discredited Avelina Cadag’s testimony for inaccuracies, and convicted Pablo Lactao of rape with serious illegal detention, sentencing him to reclusion perpetua and ordering indemnity of P12,000.00. The accused appealed to the Supreme Court.
Before the Supreme Court, the accused contended that Apolonia’s testimony was riddled with inconsistencies and therefore insufficient to support a conviction beyond reasonable doubt. The Solicitor General argued that the minor discr...(Subscriber-Only)
Issues:
- Was the prosecution’s evidence—principally the uncorroborated testimony of the complainant—sufficient and credible to convict the accused beyond reasonable doubt?
- Was the accused properly convicted of the complex crime of rape with serious illegal detention, or did the facts support a different cla...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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