G.R. No. 186540 - People vs. Obina

On January 30, 1996, at approximately 1:30 a.m., a robbery with rape occurred in Brgy. Campesao, Borongan, Eastern Samar.
The criminal charge involved the taking of money and the commission of a sexual assault against a female victim identified as AAA.

The accused included Emeldo Obina (alias "Pamentolan"), Amado Ramirez, and Carlito Balagbis (alias "Masoc").
The charges differentiated between robbery with rape (for Obina) and robbery (for Ramirez and Balagbis).
Arrests were effectuated shortly after the incident, with Obina and Ramirez detained on February 7, 1996, and Balagbis on February 9, 1996.

AAA and her common-law husband, BBB, were roused from their sleep when the accused broke into their dwelling.
The accused entered through the kitchen by destroying the door shutter, and were identified by the illumination from a nearby gas lamp.

Obina, armed with a knife, demanded money from the occupants.
AAA surrendered Eight Hundred Pesos (P800.00).
Balagbis threatened BBB with a knife approximately twelve (12) inches long.
Simultaneously, Obina and his accomplices executed a robbery, while Obina committed the act of rape against AAA by force and intimidation.
A threatening voice from beneath the house, recognized as belonging to Amado Ramirez, further intimidated the victims.

BBB managed to escape by jumping from a window and running toward a plantation.
During the chaos, as Balagbis and Ramirez pursued BBB, Obina took the opportunity to rape AAA.
AAA eventually managed to resist when the barking of several dogs distracted the perpetrators, allowing her to escape to a neighbor’s house for help.
Shortly thereafter, BBB and the police arrived at the scene.

On February 6, 1998, the RTC of Borongan rendered its decision.
The RTC found Obina guilty beyond reasonable doubt of the special complex crime of robbery with rape under Article 294, par. 1 of the Revised Penal Code (as amended by RA No. 7659), sentencing him to reclusion perpetua.
Balagbis and Ramirez were found guilty as co-principals of robbery under Article 294, par. 5, and were sentenced under the Indeterminate Sentence Law to imprisonment of four years and two months of prision correccional at the maximum term.
The RTC imposed a joint payment of P800.00 to the victims BBB and AAA, and awarded AAA P50,000.00 as moral damages.
Preventive detention credits were considered in determining the final sentences.

On January 30, 2008, the CA affirmed the RTC’s decision with modification.
Specifically, the CA modified the monetary award by ordering Obina to pay P50,000.00 as civil indemnity to AAA, while upholding the convictions and penalties for all accused.

The trial was conducted under the Revised Penal Code provisions specifically addressing robbery and rape (Article 294) as amended by Republic Act No. 7659.
The principles regarding preventive detention, as provided by Article 29 of the Revised Penal Code (amended by RA 6127), were applied in crediting the accused’s custody period.
Evidentiary reliance was placed on the credibility of witness testimonies, as assessed by the trial court.

Whether the Court of Appeals committed reversible error in affirming the trial court’s conviction of the accused.
Whether the CA improperly disturbed the trial court’s factual findings and credibility assessments of witnesses.

Whether sufficient evidence was presented that justified the trial court’s direct observation and conclusion regarding the credibility and truthfulness of the testimonies.
Whether the appellate court should have re-evaluated the witness evidence given the inherent deference to the trial court’s determinations.

Whether the penalty of reclusion perpetua imposed on Obina and the imprisonment terms for Ramirez and Balagbis were justified under the applicable laws.
Whether the separate awards of civil indemnity (P50,000.00) and moral damages (P50,000.00) to the victim in a rape case require additional evidentiary proof or are automatic.