Case Digest (G.R. No. 131040)
Facts:
People of the Philippines v. Michael Framio Sabagala, G.R. No. 131040, October 05, 2001, Supreme Court Second Division, Quisumbing, J., writing for the Court. The appeal assails the Regional Trial Court (RTC), Toledo City, Branch 29 decision of October 1, 1996 in Criminal Case No. TCS-1822 convicting the accused-appellant Michael Framio Sabagala of rape and sentencing him to reclusion perpetua with an order to indemnify the private complainant.On June 2, 1992 an Information for rape was filed alleging that on February 14, 1992 at about 6:00 p.m. in Barangay Punod, Pinamungajan, Cebu, Sabagala by force and intimidation had carnal knowledge of then 14-year-old student Annie P. Cosip. At arraignment the accused pleaded not guilty and trial followed.
The prosecution presented Annie, Marcelino Boro (a bystander), Dr. Alfredo Soberano (municipal health officer), and Annie’s mother, Dolores Cosip. Annie testified she was accosted, dragged into banana plants, physically overpowered despite resistance, had her dress and undergarment torn and was raped; Marcelino corroborated hearing shouts and observing the accused with lowered pants engaged in intercourse; Dr. Soberano examined Annie four days after the incident and found a ruptured hymen, inflamed vaginal wall and hematomas.
The defense produced several witnesses (Hilaria Sabagala, SPO4 Loreto Gines, Orlando Sabagala, Judge Esmeraldo Cantero) and the accused testified denying rape, claiming a consensual dating relationship with Annie, asserting events and movements that would place them together by prior agreement on February 14, and later saying Annie visited him in custody and sought his forgiveness. The defense also elicited testimony that Annie and others visited the accused while detained and asserted prior acquaintance between Annie and certain witnesses.
On October 1, 1996 the RTC convicted Sabagala of rape under Article 335 and ordered indemnity of P30,000. Sabagala appealed to the Supreme Court, advancing errors that the trial court’s conclusion was unsupported, that it relied so...(Subscriber-Only)
Issues:
- Should the Supreme Court disturb the trial court’s findings on witness credibility?
- Did the prosecution prove beyond reasonable doubt that the accused committed rape?
- Are the damages awarded by the trial court adequ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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