Case Digest (G.R. No. L-33772)
Facts:
In People of the Philippines vs. Adel Tuangco, Nelson Pineda Jr. and Sonny Tuangco (G.R. No. 130331, November 22, 2000), the naked cadaver of Aurea Eugenio, a bookkeeper at Centro Escolar University Credit Cooperative, was discovered on January 4, 1995 beside a creek in Apalit, Pampanga. Her body bore multiple stab wounds to the neck, fresh hymenal lacerations, and extensive signs of sexual abuse. On May 18, 1995, two informations were filed against Adel Tuangco y Dizon, Nelson Pineda Jr. alias “Jun Tattoo,” and Sonny Tuangco y Dizon alias “Baba,” charging them with (1) theft (Criminal Case No. 95-1609(M)) and (2) rape with homicide (Criminal Case No. 95-1610(M)). During trial, the principal eyewitness was Silvestre Sanggalan, a deaf-mute, who testified via a certified sign language interpreter that he observed the accused and their companion drinking, follow the victim into a rice field, push and stab her, insert a bottle into her vagina, rape her in succession, and then stealCase 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)