Case Digest (G.R. No. 177756)
Facts:
People of the Philippines v. Salvador Nieto y Cabalse @ Ador, G.R. No. 177756, March 03, 2008, Supreme Court Third Division, Chico-Nazario, J., writing for the Court.The People charged Salvador Nieto y Cabalse @ Ador with two counts of rape by means of force, alleged to have been committed on 30 December 1999 and 3 January 2000, in two separate Informations filed on 13 March 2000 and prosecuted under Article 335 of the Revised Penal Code as amended by Republic Act No. 8353. The victim, identified in the records as AAA pursuant to this Court’s confidentiality rules, was proven by psychological testing to be a severe mental retardate with an I.Q. of 30 and a mental age of five years and three months.
At arraignment on 17 April 2000 the accused pleaded not guilty; trial followed. The prosecution presented the testimony of AAA, a police investigator (SPO3 Maximiano Balelo), the medico-legal officer (Dr. Francisco Llamas), and a psychologist (Ruby Martinez Bell), together with written police and medico-legal reports. AAA testified that the accused forced her at separate times to a nearby ricefield and had sexual intercourse with her; Dr. Llamas testified to a healed hymenal laceration consistent with penile penetration; the psychologist testified to AAA’s severe mental retardation. The defense offered denial and alibi, presenting several witnesses including the accused and close relatives who claimed he was at a barangay dance or at his brother’s house on the relevant dates.
The Regional Trial Court (RTC), Branch 46, Urdaneta City, rendered judgment on 15 September 2000 convicting the accused in both Criminal Cases No. U-10586 and U-10587 of simple rape and sentencing him to reclusion perpetua in each case, awarding P50,000 civil indemnity and P20,000 exemplary damages in each count. The records were transmitted to the Court of Appeals pursuant to People v. Mateo. On appeal, the Court of Appeals (CA) in CA-G.R. CR-HC No. 02006 issued a decision dated 31 October 2006 affirming the RTC conviction but modifying the awards to include an additional P50,000 moral damages for each count.
The accused filed a Notice of Appeal to the Supreme Court. This Court, by resolution dated 11 July 2007, took the case and allowed the parties to ...(Subscriber-Only)
Issues:
- Did the RTC err in convicting the accused given alleged discrepancies in the victim’s testimony and her mental condition?
- Were the accused’s defenses of denial and alibi sufficient to overturn the conviction?
- Are the awards of civil indemnity, exemplary damages, and moral damages proper u...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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