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:
- The Supreme Court affirmed the trial court's decision that there was sufficient evidence to convict Sultan of robbery.
- The Supreme Court affirmed the trial court's decision that there was sufficient evidence to convict Sultan of rape.
- The Supreme Court ruled...(Unlock)
Ratio:
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.
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.
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
Case Digest (G.R. No. 132470)
Facts:
The case of "People vs. Sultan" involves the accused-appellant Fernando Sultan y Lato, who was charged with the special complex crime of robbery with rape. The incident occurred on June 2, 1997, at around 9:00 PM in Novaliches, Quezon City. The complainant, Juditha M. Bautista, testified that she was accosted by Sultan, who pointed a sharp instrument at her neck and announced a "hold-up." Sultan then took her valuables, including a wristwatch, ring, earrings, necklace, and cash amounting to P130.00. Subsequently, he took her to his house, where he raped her twice under threat and intimidation. Juditha managed to convince Sultan to let her go home to get her things for a supposed elopement. She immediately 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 brought to the barangay hall and later to the police headquarters, where Juditha identified him as her assailant. An Information for robbery with rape was filed against Sultan, who claimed that the sexual intercourse was consensual. The trial court found Juditha's testimony credible and convicted Sultan, sentencing him to reclusion perpetua and ordering him to pay damages. Sultan appealed the decision, arguing that there was no convincing proof of his guilt.
Issue:
- Was there sufficient evidence to convict Fernando Sultan y Lato of the crime of robbery?
- Was there sufficient evidence to convict Fernando Sultan y Lato of the crime of rape?
- Should the additional rapes committed on the same occasion be considered as an aggravating circumstance?
Ruling:
- The Supreme Court affirmed the tr...