Case Digest (G.R. No. 143124)
Facts:
People of the Philippines v. Anthony Sandig y Espanola, G.R. No. 143124, July 25, 2003, First Division, Azcuna, J., writing for the Court.On February 2, 1999 an information was filed in the Regional Trial Court (RTC), Branch 109, Pasay City, accusing Anthony Sandig y Espanola (appellant) of rape for allegedly having carnal knowledge, by means of force and intimidation and with the use of an ice pick, of AAA, a 13‑year‑old girl, on or about January 21, 1999 in Pasay City. After arraignment appellant pleaded not guilty and the case proceeded to trial. The prosecution presented AAA, a physician from the Philippine General Hospital (PGH) Child Protection Unit, and AAA’s mother. AAA testified that she and a friend went to a customary fraternity meeting at an unfinished building where appellant, who instructed others to go downstairs, remained alone with her, pointed an ice pick at her, forced intercourse and threatened to kill her if she revealed the incident; she reported the matter on February 1, 1999 and a PGH examination showed healed hymenal lacerations “definitely indicative of previous penetration.”
The defense presented appellant and AAA’s friend Geraldyn de la Cruz. Appellant denied the charges, asserting an alibi supported by an entry in the barangay blotter that he had been engaged in a fistfight elsewhere that night and had hidden afterward; he also claimed a prior brief consensual relationship with the complainant (the “sweetheart theory”). Geraldyn testified she did not see appellant at the scene and said AAA later told her she had sex with a different male (Richard Andrada).
The RTC, finding the complainant’s testimony credible and rejecting the alibi and the sweetheart defense, convicted appellant of rape on February 28, 2000 and sentenced him to reclusion perpetua, awarded P75,000 as civil indemnity and P50,000 as moral damages. Appellant appealed to the Supreme Court, which reviewed the trial cour...(Subscriber-Only)
Issues:
- Did the trial court err in convicting appellant of rape when the defense pointed to alleged inconsistencies in the complainant’s testimony, an alibi reflected in the barangay blotter, and the asserted “sweetheart” (consensual) relationship?
- Were the awards of civil indemnity and moral damages appropriate and,...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)