Case Digest (G.R. No. 131823)
Facts:
People of the Philippines v. Isagani Paraiso y Hutalla, G.R. No. 131823, January 17, 2001, Supreme Court En Banc, Per Curiam, is an automatic review of a death-penalty conviction for rape with homicide rendered by the Regional Trial Court (Branch 61), Gumaca, Quezon in a judgment dated September 29, 1997.The People (plaintiff-appellee) charged Isagani Paraiso y Hutalla (accused-appellant) by information with raping and fatally hacking AAA, a 13-year-old minor, on or about August 5, 1994. During arraignment on December 17, 1996, appellant pleaded not guilty and trial on the merits ensued. The RTC found appellant guilty beyond reasonable doubt and sentenced him to death, imposed accessory penalties, awarded P150,000.00 for actual and moral damages and P50,000.00 indemnity for death.
At trial the prosecution relied principally on eyewitness Benny Reoveros, who testified he heard AAA cry, approached, saw appellant carry the child, undress and rape her for about five minutes, then hack her neck with an 18-inch bolo; he identified appellant positively despite being related by affinity. The Municipal Health Officer, Dr. Manuel L. Salaveria, performed the post-mortem (Exh. B) showing multiple hack wounds, internal and external hemorrhage, ruptured hymen and perineal lacerations; cause of death was cardio-respiratory arrest due to severe hemorrhage secondary to multiple hack wounds.
Appellant offered an alibi: he claimed to have been sleeping at home from about 2:30 p.m. to 6:00 p.m., corroborated by his cousin Letecia Buizon, who said she found him sleeping at 3:00 p.m. and again at 5:00 p.m. The defense also pointed to alleged flaws in Reoveros’ testimony (delay in identification, misstatement about blood relationship, and improbability of commission in broad daylight). The defense further asserted an offer of P30,000.00 to the victim’s father as a settlement; the prosecution characterized that as an implied admission.
Pursuant to Section 10, Rule 122 of the Revised Rules of Court (automatic review of death sentences), the case was forwarded to the Supreme Court. On January 17, 2001 the Court, in an en banc Per Curiam decision, affirmed the RTC conviction a...(Subscriber-Only)
Issues:
- Did the trial court commit reversible error in finding appellant guilty beyond reasonable doubt in light of alleged defects in the eyewitness’s testimony (delay in identification, misstatement about relationship) and the improbability of the crime in broad daylight?
- Was appellant’s defense of alibi sufficient to overcome the positive identification and other evidence?
- Were the penalties and damages imposed by the trial court proper, including imposition of death under Article 335 (as amended by R.A. No. 7659)...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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