Title
People vs. Sanchez
Case
G.R. No. 121039-45
Decision Date
Jan 25, 1999
Brutal 1993 rape-slay of Eileen Sarmenta and Allan Gomez by Mayor Sanchez and accomplices; upheld convictions for rape with homicide, rejecting alibi defenses.

Case Digest (G.R. No. 157766)
Expanded Legal Reasoning Model

Facts:

  • The Crime
    • On the night of June 28, 1993, Mayor Antonio Sanchez and co-accused George Medialdea, Zoilo Ama, Baldwin Brion, Luis and Rogelio Corcolon, and Pepito Kawit abducted university students Eileen Sarmenta and Allan Gomez at UP Los Baños.
    • The victims were taken to Erais Farm (owned by Sanchez), where Sarmenta was gang-raped and Gomez beaten. They were then driven toward Calauan; Gomez was shot dead en route. At a sugarcane field in Barangay Mabacan, Sarmenta was raped in succession by the accused and finally killed.
  • Prosecution Evidence
    • Key witnesses Aurelio Centeno and Vicencio Malabanan (co-conspirators turned state witnesses) testified to each accused’s role from abduction through the killings and rape.
    • Forensic corroboration included:
      • A belt-loop from Sarmenta’s shorts found at Erais Farm matching her garment.
      • An M16 shell at Gomez’s death site ballistically linked to Luis Corcolon’s rifle.
      • Autopsy by Dr. Villaseñor confirming multiple lacerations of Sarmenta’s hymen, contusions, and presence of spermatozoa.
  • Defense Case
    • All accused invoked alibis and blamed “Kit Alqueza” (a university student) for the crime. They described being elsewhere conducting police operations or at home, and claimed coerced confessions under torture and duress by law enforcement.
    • Medical and other defense witnesses offered alternative explanations (e.g., Dr. Ernesto Brion contested the rape findings).
  • Trial Court Decision
    • On March 11, 1995, the Pasig RTC Branch 70 convicted each accused of seven counts of rape with homicide, imposing seven reclusion perpetua sentences per defendant.
    • Civil indemnities ordered jointly and severally:
      • Actual damages: ₱3,432,650 (Sarmenta family), ₱3,484,000 (Gomez family).
      • Moral damages: ₱2,000,000 each.
      • Attorney’s fees and litigation expenses.

Issues:

  • Credibility of State Witnesses
    • Whether Centeno’s and Malabanan’s testimony should be discredited due to alleged contradictions in their sworn statements and possible coercion.
  • Viability of Alibi and Alternative-Suspect Defense
    • Whether the accuseds’ alibis and the “Kit Alqueza” theory create reasonable doubt.
  • Impact of Pre-Trial Publicity
    • Whether extensive media coverage denied the accuseds a fair and impartial trial.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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