Case Digest (G.R. No. 113022-24)
Facts:
People of the Philippines v. Teofilo Seranilla y Francisco, Leo Ferrer y Padilla, Edmundo Hentolia y Retaa, Daniel Almorin y Balbin and Carlos Cortez, Jr., G.R. Nos. 113022-24, December 15, 2000, Supreme Court First Division, Pardo, J., writing for the Court.The People of the Philippines (plaintiff-appellee) filed four informations on October 6, 1992 charging Teofilo Seranilla y Francisco, Leo Ferrer y Padilla, Edmundo Hentolia y Retaa, Daniel Almorin y Balbin and Carlos Cortez, Jr. with rape with homicide (Criminal Cases Nos. 1945–1948, raffled to Branch 77, RTC San Mateo, Rizal). At arraignment on November 3, 1992 each accused pleaded not guilty and the four cases were tried jointly.
On September 20, 1992 the victim, Maria Victoria P. “Vicky” Santos, left work and did not return home. Her naked, decomposing body was found on September 25, 1992 in a grassy area in Barangay Ampid, San Mateo; identification was made by her mother. Dr. Dario L. Gajardo performed the post-mortem and concluded death from cardio-respiratory arrest due to shock and hemorrhage secondary to an extensive incised wound to the neck; autolysis of internal organs prevented conclusive identification of other injuries.
Police arrested Teofilo Seranilla, Leo Ferrer, Daniel Almorin and Edmundo Hentolia on September 25, 1992; Carlos Cortez, Jr. was brought in for questioning and executed a sworn statement and later testified, narrating that on the night of September 20 he and the others were drinking when they accosted Vicky, who was knocked unconscious, carried to a grassy area, and raped in successive turns while other accused held her; Carlos said he left before one accused finished. Carlos implicated himself and the others; he later escaped detention on January 20, 1993.
During trial the accused offered alibi defenses — Teofilo produced a work time card claiming he arrived home at 10:35 p.m., Edmundo claimed he was at home nursing a wounded leg, Daniel said he was helping in his mother’s store, and Leo claimed to be at home some 400 meters away — but none produced corroborating evidence. Prosecution also produced witness Rolando (Ronaldo) Franco who said he saw the accused drinking in the vicinity on the night in question.
On August 9, 1993 the Regional Trial Court, Branch 77, found all accused guilty beyond reasonable doubt of rape with homicide and sentenced each to reclusion perpetua on each count and...(Subscriber-Only)
Issues:
- Was the conviction of the accused for rape with homicide supported by credible evidence beyond reasonable doubt?
- Did the accused successfully establish alibi sufficient to overthrow the prosecution’s case?
- Was there sufficient proof of conspiracy or concerted action among the accused?
- Were the awards for civil indemnity and moral damages proper and, if not, wh...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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