Title
People vs. Tanail y Borbe
Case
G.R. No. 125279
Decision Date
Jan 28, 2000
Jesus Tanail was found guilty of rape, as the court deemed the victim’s consistent testimony credible despite minor inconsistencies, and rejected the defense arguments regarding the impossibility of the act and the relevance of physical evidence.
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Case Digest (G.R. No. 125279)

Facts:

  • Jesus Tanail y Borbe is the accused-appellant; Marites S. dela Cruz is the victim.
  • The incident occurred on October 5, 1993, in Malolos, Bulacan, Philippines.
  • Thirteen-year-old Marites was home alone while her mother washed clothes nearby, and her father was farming.
  • Tanail, known to the family, asked to watch television and was let inside by Marites.
  • Once inside, he brandished a kitchen knife, tied her hands and feet, gagged her, and forced her into her room.
  • He raped her in a "dog-style" position, causing her pain and preventing her from screaming.
  • After the assault, he untied her and threatened to kill her if she told anyone.
  • This abuse continued until January 1994, when Marites' mother discovered her pregnancy.
  • Marites revealed that Tanail was the father after being confronted by her mother.
  • A complaint was filed against Tanail, leading to his arrest on January 9, 1994.
  • The prosecution presented medical evidence confirming the sexual assault.
  • Tanail denied the charges, claiming he was at a quack doctor’s house during the incident.
  • The Regional Trial Court found him guilty of rape and sentenced him to reclusion perpetua, along with monetary damages.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the Regional Trial Court's decision, finding Jesus Tanail y Borbe guilty beyond reasonable doubt of rape.
  • The Court upheld the trial court's assessment o...(Unlock)

Ratio:

  • The Supreme Court emphasized the importance of the trial court's findings on witness credibility, given its ability to observe witness demeanor.
  • Minor inconsistencies in Marites' testimony were seen as indicative of truthfulness rather than a lack of credibility.
  • The victim's fear of retaliation explained her delay in reporting the crime, a common occurrence in sexual assault cases.
  • The absence of blood during the first sexua...continue reading

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