Case Digest (G.R. No. 218804)
Facts:
People of the Philippines v. Leonardo Quiapo @ "Lando", G.R. No. 218804, August 06, 2018, Supreme Court First Division, Del Castillo, J., writing for the Court.The accused-appellant, Leonardo Quiapo (appellant), was charged in six separate Informations before the Regional Trial Court (RTC) of Liloy, Zamboanga del Norte, Branch 28 (Criminal Case Nos. L-0098 to L-0103) with rape under Article 335 of the Revised Penal Code. Two victims are identified in the records as MMM (11 years old) and AAA (12 years old). The Informations allege occurrences between April and September 1996 at locales in Zamboanga del Norte.
At trial the prosecution presented the victims’ accounts: MMM testified to two separate rapes by appellant on 20 and 21 September 1996, describing force, threats (including an air gun), pain and subsequent vaginal bleeding; AAA testified to multiple assaults in April–May 1996, including episodes while fetching water and while sleeping in the family dwelling, likewise describing threats, pain and bleeding. Both victims underwent physical examinations by Dr. Joshua G. Brillantes on May 29, 1997, who observed healed complete laceration of the hymen and signs consistent with prior penetration (admission of fingertip without resistance). Appellant denied the charges, asserting alibi and fabrication motivated by a purported grudge against him.
On September 5, 2008 the RTC convicted appellant: guilty of attempted rape in Criminal Case No. L-0100 and guilty of multiple counts of consummated rape in the other cases, imposing indeterminate and reclusion perpetua penalties and awarding damages to the victims. Appellant appealed to the Court of Appeals (CA).
On April 24, 2015 the CA in CA-G.R. CR HC No. 00669-MIN affirmed with modification: it found appellant guilty of statutory rape (Article 266-A(1)(d)) in Criminal Case Nos. L-0098 and L-0099 (victim MMM), guilty of simple rape (Article 266-A(1)(a)) in Criminal Case Nos. L-0101, L-0102 and L-0103 (victim AAA), and guilty of attempted rape in Criminal Case No. L-0100; the CA imposed reclusion perpetua without eligibility for parole for the rape convictions and adjusted monetary awards for civil indemnity, moral and exemplary damages, plus interest. Appellant elevated the matter to the Supreme Court; the Court issued a Resolution on August 5, 2015 requiring supplemental briefs, but the parties instead adopted their CA briefs.
The Supreme Court resolved the appeal by affirming the CA’s factual findings and convictions largely for the reasons that the victims...(Subscriber-Only)
Issues:
- Did the trial court and the Court of Appeals err in accrediting the testimonies of the victims and convicting appellant (procedural issue of witness credibility and appreciation of evidence)?
- Do inconsistencies in the victims’ testimony as to time, place and date, and their delayed reporting, render the testimonies unreliable and require acquittal?
- Was appellant properly convicted of (a) statutory rape in Criminal Case Nos. L-0098 and L-0099, (b) simple rape in Criminal Case Nos. L-0101–L-0103, and (c) attempted rape in Criminal Case No. L-0100?
- Should th...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)