Case Digest (G.R. No. 94309)
Facts:
People of the Philippines v. Rene Paciente, G.R. No. 94309, June 18, 1992, Supreme Court Third Division, Romero, J., writing for the Court (Gutierrez, Jr., (Chairman), Feliciano, Bidin, and Davide, Jr., JJ., concur).The complainant, Norma Dulfo, an 18-year-old, attended a fiesta in Talisay, Sara, Iloilo on April 23, 1984. After spending the evening at several houses and the dance hall, she accepted an offer from Rene Paciente (a relative by affinity and husband of her second cousin) to ride home on his motorcycle. Instead of proceeding directly to her town, the accused diverted onto an isolated, unused road; there he forcibly restrained and sexually assaulted Norma. She resisted, scratched his face, lost consciousness after being struck, and later regained consciousness to find herself naked and in pain.
Norma left for Iloilo City early the next morning and, at about 2:30 a.m., submitted to a medico-legal examination at Sara District Hospital; Dr. Raul Banias reported abrasions and that the vagina admitted one finger with ease and noted menstrual bleeding but no lacerations. Norma turned over torn and soiled clothing to PC Sgt. Dollete and executed a written statement. A criminal complaint was filed before the Municipal Circuit Court of Sara on April 27, 1984, where an arrest warrant issued; accused was detained, later transferred among police facilities, and an information charging rape was filed before the Regional Trial Court (RTC) of Iloilo on August 16, 1984. Accused pleaded not guilty on arraignment on October 24, 1984.
After trial the RTC (Judge Julian Y. Ereno) found Rene Paciente guilty of rape and sentenced him to suffer reclusion perpetua and ordered indemnity in the amount of P25,000; the accused appealed. The primary contention on appeal was whether the RTC erred in convicting him given alleged inconsistencies in Norma’s statements, an asserted alibi that the accused remained at the dance hall, and deficiencies in the medico‑legal evidence (notably, no sperm test). The Supreme Court reviewed the recor...(Subscriber-Only)
Issues:
- Was the conviction of Rene Paciente for rape supported by evidence beyond reasonable doubt?
- Did the alleged inconsistencies in the complainant’s statements, the accused’s alibi, and the absence of a sperm test destroy the prosecution’s case?
- Was the award of civil indemnity appropriate and, if so, what...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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