G.R. No. L-59234 - Taxicab Operators of Metro Manila, Inc. vs. Board of Transportation

On April 25, 1975, 17-year-old Thelma Agustin left a moviehouse in the poblacion of Alicia, Isabela after watching a film, and after her companion, her cousin Fideliza Agustin, failed to rejoin her.
While walking approximately 500 meters from the poblacion toward her barrio of Linglingay, Thelma was waylaid by three men under the bright moonlight.

The accused—Constantino Peralta y Dasuga alias “Og”, Antolin Pua alias “Bondying”, and an unidentified third man—approached Thelma.
Upon confronting her, the trio forcibly grabbed and kissed her; Peralta held her hands, Pua pulled her hair, and the third man restrained her feet.
During the assault, when Thelma attempted to cry out, Peralta’s forceful action (boxing her in the abdomen) rendered her unconscious.
When she awoke, Thelma discovered herself naked with her clothes scattered, evidence of physical injuries (pain in her buttocks and vagina), and signs of struggle with her blouse and pantsuit disarranged.

Thelma regained consciousness at a relative’s (her aunt Carolina Agustin’s) home, where she immediately reported that she had been raped by three men, explicitly naming Constantino Peralta.
Soon after the incident, her father, Fidelino Agustin, transported her via tricycle to obtain medical treatment.
A medical examination conducted at the Emergency Hospital in Cauayan, Isabela, revealed:

Following the assault, Thelma and her parents promptly reported the crime to the local Chief of Police, leading to the identification of Peralta during a police lineup procedure.
Constantino Peralta was apprehended shortly after, while other accused individuals were either later acquitted or remained unidentified.
A complaint for rape was subsequently filed against Peralta and his co-accused (with an amended complaint also naming Antolin Pua).

The trial court found Constantino Peralta guilty of rape and sentenced him to seventeen (17) years, four (4) months, and one (1) day of reclusion temporal, along with an award of P50,000.00 to the offended party.
Antolin Pua was acquitted for insufficiency of evidence.
The evidence of Thelma’s testimony was corroborated by the physical/medical findings, witness identifications, and circumstantial evidence.

The accused asserted that they were in a different location on the night of the incident based on their alibi:

They claimed to have been at the Macaraeg Restaurant in Alicia, Isabela, where they stayed until around 9:00 o’clock before retiring to sleep in their weapons carriers in the public market area.

Defense witnesses, including Felicidad Macaraeg, Patrolman Federico Valdez, and Crispin Cabantac, testified in support of their alibi.
However, inconsistencies in the defense testimonies and accounts—such as the feasibility of being in two places at once and discrepancies in the timeline—undermined the credibility of the alibi.

Whether Thelma Agustin’s account—detailing the assault, her injuries, and her recognition of Peralta—was credible and untainted by exaggeration or coaching.
The sufficiency and reliability of her identification of Constantino Peralta as one of the perpetrators, given that the incident occurred at night under moonlight conditions.

Whether the physical evidence and medical findings (contusions, lacerations, and the detection of sperm) corroborated the victim’s narrative of rape definitively.
The reliability of the medical diagnosis in establishing that the injuries were indeed the result of a recent rape.

If the alibi presented by the accused—and corroborated by defense witnesses—is substantial enough to cast doubt on the occurrence of the rape near the poblacion rather than at the restaurant.
The consistency and reliability of the defense witnesses’ testimonies in light of conflicting evidence regarding the accused’s whereabouts.

Whether the initial sentencing (17 years, 4 months, and 1 day of reclusion temporal) was proper given that the crime of rape by two or more persons was punishable by reclusion perpetua as an indivisible penalty during the relevant period.
The need to assess aggravating and mitigating circumstances under the precedent set by People vs. Arizala and other relevant cases.