Case Digest (G.R. No. 103967) Core Legal Reasoning Model
Facts:
The case involves Generoso Sujetado y Esmellarin as the accused-appellant, charged with the crime of rape against Livy Montelibano, a minor under twelve years of age, occurring on March 21, 1988, in Bacolod City, Philippines. Livy, born on June 28, 1976, was allegedly invited to the house of the accused by him, who forcefully brought her to his home when she refused. Inside, he reportedly made her lie down, removed her clothes, and engaged in sexual intercourse with her. After the act, he attempted to give her a P5.00 bill. Livy's cousin, Jeffrey Samartin, testified that he saw Livy coming out of the accused's house while pulling up her pants, and shortly afterward, Livy confided in him about the assault. Subsequently, Livy’s mother, Marilyn Montelibano, took her for a medical examination that revealed old healed hymenal lacerations and signs of previous sexual activity.
The accused, a 58-year-old, denied the allegations, asserting he had been busy attending to custome
Case Digest (G.R. No. 103967) Expanded Legal Reasoning Model
Facts:
- On March 21, 1988, the accused, Generoso Sujetado y Esmellarin, was charged with raping Livy Montelibano, then 12 years old, in Bacolod City. The charge alleged that by means of force, violence, and intimidation, he had carnal knowledge of the minor against her will.
- Livy Montelibano, whose mother is Marilyn Montelibano, alleged that the accused invited her to his house to “pull out his gray hair.” After she initially refused, he allegedly forced her, led her to his house, made her lie on a bed, and removed her clothing before committing the act. He reportedly even placed a five-peso bill on her palm after the sexual act.
- Several prosecution witnesses testified regarding the incident, including Jeffrey Samartin, Livy’s cousin, who stated that he saw the accused descending from his house with Livy soon after the alleged act.
- An examination conducted at the Provincial Hospital revealed redness and healed hymenal lacerations and noted a whitish discharge that was interpreted by some as seminal fluid. However, these lesions were later characterized as “old healed” and consistent with previous sexual relations Livy had with another man.
- The accused denied the charge, testifying that on the morning in question he left his house at 6:00 a.m. for work, and that between 8:30 and 11:30 a.m., he was occupied at his store attending to a customer, Clemens Mabugat, with his wife, grown-up children, and grandchildren present in the house. He further contended that the rape charge was fabricated so that he could be dismissed as overseer of Hacienda Flora in favor of Roberto Naranja, a relative of Livy’s mother.
Issues:
- Whether the evidence on record, particularly the prosecution’s reliance on the complainant’s testimony and the alleged medical findings, was sufficient to prove the crime of rape beyond reasonable doubt.
- Whether the testimony of prosecution witnesses could be reconciled with the strong defense evidence indicating that the accused was in the company of family members and attending to business during the time the alleged rape occurred.
- Whether the inconsistencies and factual improbabilities—as raised by the defense regarding the timing of events and behavior immediately after the alleged crime—undermine the prosecution’s case.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)