Title
People vs. Obtinalia
Case
G.R. No. L-30190
Decision Date
Apr 30, 1971
In summary, the accused were found guilty of robbery in band with rape based on the positive evidence presented by the prosecution. The defense of alibi was deemed weak and unconvincing. The court ruled that the death penalty should apply in cases where rape is committed by two or more persons. The court also considered the aggravating circumstances of the crime being perpetrated in the dwelling of the victims and the presence of the woman's husband during the rapes. The accused were sentenced to death and ordered to pay the victims and indemnify Rufina Pitalbero.
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Case Digest (G.R. No. L-30190)

Facts:

  • Case Title: People vs. Obtinalia (G.R. No. L-30190)
  • Decision Date: April 30, 1971
  • Respondents: Mariano Obtinalia, Teoly Ubalde (alias "Jorge"), Jimce Ubalde
  • Charges: Robbery in band with rape
  • Incident Date: June 5, 1968
  • Location: Agno, Pangasinan
  • Details of the Crime:
    • Accused entered the home of spouses Clemente Fontanilla and Rufina Pitalbero armed with firearms and bolos.
    • Mr. Fontanilla was assaulted, bound, and threatened.
    • Mrs. Pitalbero was raped by all three accused in front of her husband.
  • Trial Court's Decision: Convicted the accused based on victim testimonies; sentenced to death.
  • Appeal: Accused claimed an alibi and questioned the sufficiency of the evidence.
  • Supreme Court's Review: Upheld the trial court's decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the trial court's ruling.
  • The guilty verdict for robbery in band with rape was upheld.
  • The Court found the evidence, particularly the victims' testimonies, sufficient to establish guilt.
  • The death penalty was deemed appropriate due to aggravating cir...(Unlock)

Ratio:

  • The victims' testimonies were credible and compelling, surviving rigorous cross-examination and supported by prompt police reporting.
  • The defense of alibi was weak and did not outweigh the prosecution's strong evidence.
  • The absence of spermatozoa in the medical examination did not negate the occurrence of rape, as other explanations were possible.
  • The Court stated that the death penalty was appropriate...continue reading

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