Title
People vs. Sultan
Case
G.R. No. 132470
Decision Date
Apr 27, 2000
The accused-appellant was found guilty of the special complex crime of robbery with rape based on the credible testimony of the complainant. The court ruled that the complainant's testimony was sufficient evidence to sustain a conviction for robbery, as it established the taking of her cash and valuables by the accused-appellant. The court also found that all the elements necessary for the crime of robbery were present. Additionally, the court ruled that the accused-appellant used intimidation to commit the rape, which was sufficient to make the complainant submit against her will. The court affirmed the trial court's decision and sentenced the accused-appellant to reclusion perpetua. The court also ordered the addition of P50,000.00 as civil indemnity in accordance with prevailing jurisprudence.
Font Size

Case Digest (G.R. No. 132470)

Facts:

  • Fernando Sultan y Lato was charged with robbery with rape.
  • The incident occurred on June 2, 1997, at around 9:00 PM in Novaliches, Quezon City.
  • Juditha M. Bautista testified that Sultan accosted her, pointed a sharp instrument at her neck, and announced a "hold-up."
  • Sultan took her wristwatch, ring, earrings, necklace, and P130.00 in cash.
  • Sultan then took Juditha to his house and raped her twice under threat and intimidation.
  • Juditha convinced Sultan to let her go home to get her things for a supposed elopement.
  • She reported the incident to her sister, who informed their brother, SPO1 Fernando M. Bautista.
  • A plan was devised to arrest Sultan, which was successfully executed.
  • Sultan was identified by Juditha and brought to the barangay hall and later to the police headquarters.
  • An Information for robbery with rape was filed against Sultan, who claimed the sexual intercourse was consensual.
  • The trial court found Juditha's testimony credible, convicted Sultan, sentenced him to reclusion perpetua, and ordered him to pay damages.
  • Sultan appealed, arguing there was no convincing proof of his guilt.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court affirmed the trial court's decision that there was sufficient evidence to convict Sultan of robbery.
  2. The Supreme Court affirmed the trial court's decision that there was sufficient evidence to convict Sultan of rape.
  3. The Supreme Court ruled...(Unlock)

Ratio:

  1. Robbery Conviction:

    • Juditha's testimony about Sultan taking her cash and valuables was credible and sufficient for a robbery conviction.
    • All elements of robbery were present: personal property belonging to another, unlawful taking, intent to gain, and violence or intimidation.
    • The Court dismissed Sultan's argument about Juditha's failure to ask for her belongings back, noting her actions were likely to avoid arousing suspicion.
  2. Rape Conviction:

    • Juditha's testimony was credible and corroborated by medical findings of fresh lacerations in her hymen.
    • Sultan used sufficient intimidation by threatening Juditha with an ice pick, making her submit against her will.
    • Intimidation is subjective and should be viewed from the victim's perspective; Juditha's fear was reasonable under the circumstances.
  3. Additional Rapes:

    • The Supreme Court referred to previous rulings, including People v. Regala, stating additional rapes on the same occasion should not be considered an aggravating ci...continue reading

Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.

© 2024 Jur.ph. All rights reserved.