Title
People vs. Teves
Case
G.R. No. 121994
Decision Date
Oct 18, 2000
The court convicted the uncle of rape, prioritizing the young girl's credible testimony despite minor inconsistencies.
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Case Digest (G.R. No. 121994)

Facts:

  • The case involves the People of the Philippines as the plaintiff-appellee against Angeles Teves y Tapel, the accused-appellant.
  • The Supreme Court rendered its decision on October 18, 2000.
  • The Regional Trial Court of South Cotabato, Branch 26, convicted Teves of rape and sentenced him to reclusion perpetua.
  • Teves was ordered to indemnify the victim, Mary Jane Vargas, in the amount of P50,000.
  • The information was filed on November 4, 1993, by 4th Assistant Provincial Prosecutor Jerry A. Garcia.
  • The rape occurred on August 22, 1993, in Sitio Lutayan, Barangay Poblacion, Lake Sebu, South Cotabato.
  • Mary Jane Vargas, then 15 years old, accompanied her uncle, Teves, to deliver her sister's allowance.
  • After spending the day together, they returned home around 7:00 p.m. and decided to walk due to lack of transportation.
  • Near a bridge, Teves professed his love, which Mary Jane rejected, leading to a violent confrontation.
  • Teves choked, gagged, and threatened her with a knife before raping her despite her resistance.
  • A passerby, Jerry Dolan, heard her screams and intervened, witnessing the assault.
  • Teves fled, leaving behind his shirt, while Mary Jane escaped and reported the incident.
  • During the trial, Teves claimed Mary Jane initiated sexual advances and that they had a consensual relationship.
  • The trial court found Mary Jane's testimony credible, leading to Teves' conviction on August 3, 1994.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the trial court's decision, finding no error in crediting Mary Jane's testimony.
  • The absence of physical evidence did not negate the charge of rape, as credible testimony alone suffices for conviction.
  • The Court modified th...(Unlock)

Ratio:

  • The Supreme Court upheld the trial court's findings, emphasizing the credibility of Mary Jane's consistent and compelling testimony.
  • It is improbable for...continue reading

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