Title
People vs. Tuangco
Case
G.R. No. 130331
Decision Date
Nov 22, 2000
A deaf-mute witness testified that Adel and Sonny Tuangco raped and killed Aurea Eugenio in 1995. The Supreme Court upheld their conviction, affirming the death penalty for rape with homicide and lesser penalties for theft, based on credible testimony and medical evidence.
A

Case Digest (G.R. No. L-33772)

Facts:

  • Crime and Victim Discovery
    • On the morning of January 4, 1995, the naked cadaver of Aurea Eugenio, a bookkeeper, was found beside a creek in Sitio Dalan Baka, Barangay Sulipan, Apalit, Pampanga. Her body bore multiple stab wounds to the neck and signs of sexual abuse, including bloodied private parts.
    • Medico-legal findings by Dr. Dominic Aguda: nine gaping stab wounds to the neck causing massive hemorrhage; fresh hymenal lacerations and massive blood clots in the vaginal canal from both penile penetration and insertion of a hard object; abrasions indicating struggle and possible human bites. Cause of death was severe hemorrhage secondary to multiple stab wounds.
  • Procedural History and Trial Evidence
    • May 18, 1995: Informations filed charging Adel Tuangco, Nelson Pineda Jr. (“Tatoo”), and Sonny Tuangco (“Baba”) with (a) rape with homicide under Art. 335, RPC, as amended, and (b) theft under Arts. 308–309, RPC.
    • Trial court received:
      • Eyewitness testimony of Silvestre Sanggalan, a deaf-mute, who observed the crime three and a half meters from the scene and identified the three accused by features and aliases. Interpretation was provided by certified sign-language expert Eva Sangco.
      • Alibi testimonies from Adel’s common-law wife, mother, and sister, and from Sonny claiming absence at scene.
      • Defense character attacks on Sanggalan as a drunkard and drug user; attempted impeachment by evidence of a pending rape charge against him.

Issues:

  • Whether the testimony of the deaf-mute eyewitness, Silvestre Sanggalan, is credible and sufficient for conviction despite his physical handicap and alleged inconsistencies.
  • Whether the prosecution established guilt beyond reasonable doubt for the special complex crime of rape with homicide and for theft.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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