Title
People vs. Oliquino
Case
G.R. No. 94703
Decision Date
May 31, 1993
Roberto Oliquino, alias 'Berto,' is convicted of rape due to the credible testimony of complainant Eden Argudo, irrespective of the complaint's delayed filing and the defendant's arguments.
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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

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