Case Digest (G.R. No. 238451)
Facts:
- Armando Pedido y Beloera (accused-appellant) was charged with rape against a 76-year-old woman, referred to as AAA.
- The incident occurred on the night of December 22, 2012, or early dawn of December 23, 2012, in Negros Oriental, Philippines.
- The Information alleged that the accused-appellant had carnal knowledge of AAA against her will, using force and lewd design.
- AAA's nephew, BBB, found her outside her house on December 23, 2012, and discovered blood on the floor upon bringing her inside.
- Another relative, CCC, found the accused-appellant lying on the bed and AAA bloodied on the floor.
- AAA did not provide a clear response when questioned.
- The accused-appellant fled but was later apprehended with bloodstains on his underwear and dried marijuana leaves.
- Medical examinations of AAA revealed contusions, abrasions, and severe vaginal lacerations.
- The defense did not present evidence, and a demurrer to evidence was denied.
- The Regional Trial Court (RTC) convicted the accused-appellant on May 25, 2015, sentencing him to reclusion perpetua and ordering damages to AAA.
- The Court of Appeals (CA) affirmed the RTC's ruling on November 29, 2017, with modifications to monetary awards.
Issue:
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Ruling:
- The Supreme Court dismissed the appeal, affirming the Court of Appeals' decision which upheld the RTC's conviction of the accused-appellant for rape.
- The Court found that the prosecution established the...(Unlock)
Ratio:
- The Court highlighted that the essential elements for a rape conviction include carnal knowledge and the use of force or intimidation.
- It acknowledged the challenges in proving rape, especially when the victim cannot testify, as AAA had died before her account could be presented in court.
- Direct evidence is not mandatory for conviction; circumstantial evidence can suffice if it meets specific criteria.
- The requirements for circumstantial evidence, as per Section 4, Rule 133 of the Revised Rules of Evidence, include multiple proven circumstances that lead to a conviction beyond reasonable doubt.
- Circumstantial evidence in this case included the accused-appellant being the last person with AAA, his flight from the scene, bloodstains on his underwear, an...continue reading
Case Digest (G.R. No. 238451)
Facts:
The case involves Armando Pedido y Beloera (accused-appellant) as the defendant, and the People of the Philippines as the plaintiff-appellee. The events transpired on the night of December 22, 2012, or in the early dawn of December 23, 2012, in Negros Oriental, Philippines. The accused-appellant was charged with the crime of rape against a 76-year-old woman, referred to as AAA, who was described as an old maid. The Information filed against him alleged that he had carnal knowledge of AAA against her will and consent, using force and lewd design.
On the morning of December 23, 2012, AAA's nephew, BBB, found her outside her house and led her back inside, where he discovered blood on the floor. He called another relative, CCC, who upon entering AAA's room, found the accused-appellant lying on the bed and AAA bloodied on the floor. When questioned, AAA did not provide a clear response. The accused-appellant fled the scene and was later pursued by police officers, who found him with bloodstains on his underwear and dried marijuana leaves in his possession. AAA was taken to the hospital, where medical examinations revealed contusions, abrasions, and severe vaginal lacerations indicative of trauma.
The defense did not present any evidence, and the accused-appellant filed a demurrer to evidence, which was denied. The Regional Trial Court (RTC) of Dumaguete City rendered a judgment on May 25, 2015, finding the accused-appellant guilty beyond reasonable doubt of rape, sentencing him to reclusion perpetua, and ordering him to pay damages to AAA. The accused-appellant appealed the decision to the C...