Case Digest (G.R. No. 94703)
Facts:
- Roberto Oliquino, also known as "Berto," was convicted of rape by the RTC of Calauag, Quezon, Branch 63.
- The incident occurred on August 5, 1988, involving complainant Eden Argudo, a 20-year-old college student.
- Eden was taken to Oliquino's residence for treatment of stomach pain, accompanied by her mother, Tarciana Argudo, a friend of the appellant.
- Oliquino, a known faith healer, had previously treated Eden for various ailments.
- After instructing Tarciana to pray inside his house, Oliquino led Eden to a secluded area and threatened her with a knife.
- He forced her to undress and raped her, warning her against disclosing the incident.
- Eden showed signs of emotional distress, leading her parents to seek medical help in November 1988, where it was confirmed she had been raped and was pregnant.
- A criminal complaint was filed against Oliquino on February 7, 1989.
- The defense presented witnesses claiming other patients were present, but the RTC found the evidence against Oliquino compelling.
- On June 20, 1990, the trial court convicted him of rape, sentencing him to reclusion perpetua and ordering him to pay Eden P30,000 in damages.
- Oliquino appealed, arguing the prosecution failed to prove his guilt beyond a reasonable doubt.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the conviction of Roberto Oliquino, finding that the prosecution proved his guilt beyond a reasonable doubt.
- The Court ruled that the delay in reporting the incident did not automatically render Eden's testimony incredible.
- The Court u...(Unlock)
Ratio:
- The Supreme Court emphasized that rape convictions often depend on the credibility of the complainant's testimony, as such crimes usually occur without witnesses.
- The Court noted that the prosecution's evidence must be evaluated on its own merits, and delays in reporting do not inherently undermine a victim's c...continue reading
Case Digest (G.R. No. 94703)
Facts:
The case involves the defendant-appellant Roberto Oliquino, also known as "Berto," who was convicted of rape by the Regional Trial Court (RTC) of Calauag, Quezon, Branch 63. The incident occurred on August 5, 1988, when the complainant, Eden Argudo, a 20-year-old second-year college student at the Polytechnic University of the Philippines, was taken to Oliquino's residence for treatment of stomach pain. Eden was accompanied by her mother, Tarciana Argudo, who was a friend of the appellant. Oliquino, known in the community as a faith healer, had treated Eden for various ailments in the past. On the day of the incident, after instructing Tarciana to pray inside his house, Oliquino led Eden to a secluded area at the foot of a mountain behind his house. There, he threatened her with a knife, forced her to undress, and raped her. Following the assault, he warned her not to disclose the incident, threatening to kill her and her family through a curse. Eden exhibited signs of emotional distress after the incident, which led her parents to seek medical help in November 1988. A medical examination confirmed that Eden had been raped and was pregnant. Subsequently, a criminal complaint was filed against Oliquino on February 7, 1989. During the trial, the defense presented witnesses who claimed that there were other patients present during Eden's treatment, but the RTC found the evidence against Oliqui...