Facts:

On June 24, 1990, a group of fifteen armed men invaded the residence of spouses Manuel and AAA in Casingsingan Norte, Amulung, Cagayan. The incident involved robbery and multiple rapes. Two days later, on June 26, AAA executed a sworn statement accusing Eriberto Batuelo, Elpidio Gangan, Roberto Salvador, Martin Soriano, and Roberto Balacanao of robbery with rape, which was followed by Manuel's sworn statement on June 27, identifying Soriano as one of the assailants. A criminal complaint was filed on July 2, 1990, by Police Investigator Cuntapay against the aforementioned individuals and five unidentified persons. After a preliminary examination, an information was recommended for filing on August 22, 1990.

On October 22, 1990, an anonymous letter revealed that Damaso Cabana was involved in the incident. Cabana was arrested on November 5, 1990, and subsequently confessed his participation, naming several accomplices, including Jessie Acorda, Minio Acorda, Ruben Acorda, ...

Facts:

1. Incident Overview
   On June 24, 1990, fifteen armed men stormed the house of spouses Manuel and AAA in Barangay Casingsingan Norte, Amulung, Cagayan. The perpetrators committed robbery and multiple rapes against AAA.

2. Initial Complaints and Investigation

   • On June 26, 1990, AAA executed a sworn statement identifying Eriberto Batuelo, Elpidio Gangan, Roberto Salvador, Martin Soriano, and Roberto Balacanao as among the perpetrators.
   • On June 27, 1990, Manuel also identified Soriano as one of the culprits.
   • A criminal complaint for robbery with multiple rapes was filed on July 2, 1990, against Balacanao, Batuelo, Gangan, Salvador, Soriano, and five John Does.

3. Reinvestigation and Additional Accused

   • An anonymous letter dated October 22, 1990, implicated Damaso Cabana as one of the masterminds.
   • Cabana was arrested on November 5, 1990, and executed a sworn statement on November 6, 1990, admitting his participation and identifying his accomplices, including Jessie Acorda, Herminio Acorda, Ruben Acorda, Tacio Acorda, Villamor Agana, Elvis Bangayan, Abraham Camayang, Lorenzo Caronan, Gil Tambiao, and others.
   • A reinvestigation led to the filing of an Information on August 29, 1991, charging Cabana and fourteen others with Robbery with Rape.

4. Trial Proceedings

   • The accused pleaded not guilty, except for Damaso Cabana, who was discharged as a state witness.
   • The prosecution presented evidence, including testimonies from AAA, Manuel, and Cabana, detailing the robbery and rapes.
   • The defense relied on alibis, claiming they were not present at the scene of the crime.

5. Trial Court Decision

   • The trial court found the accused guilty beyond reasonable doubt of Robbery with Rape, sentencing them to reclusion perpetua and ordering them to pay damages.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Identity of the Accused

   • The prosecution established the identity of the accused through the testimonies of AAA, Manuel, and Cabana. The accused were positively identified as participants in the crime.

2. Credibility of Witnesses

   • The inconsistencies in AAA's testimony during the preliminary investigation were due to nervousness and confusion, which did not undermine her credibility. The Court found her testimony credible and consistent during the trial.

3. Alibi Defense

   • The alibis presented by the accused were insufficient to exonerate them. The accused failed to prove that it was physically impossible for them to be at the scene of the crime.

4. Aggravating Circumstances

   • The trial court erred in appreciating the aggravating circumstances of abuse of superior strength and ignominy, as these were not alleged in the Information. The Court ruled that such circumstances cannot be appreciated if not properly alleged.

5. Award of Damages

   • The Court reduced the award of actual damages to P10,000.00, as the prosecution failed to provide sufficient evidence for the value of the stolen items. The Court also reduced the moral damages to P50,000.00 for each count of rape and awarded P50,000.00 to Manuel as moral damages.

Conclusion:

The Supreme Court upheld the conviction of the accused for Robbery with Rape but modified the damages awarded. The Court emphasized the importance of proper allegations of aggravating circumstances and the need for sufficient evidence to support claims for damages.