Case Digest (G.R. No. 131824-26)
Facts:
- Federico Ulgasan faced three counts of statutory rape against 11-year-old Noella Garolacan.
- The assaults occurred on February 15, March 6, and April 6, 1997, in Bacolod City, Philippines.
- Ulgasan lured Noella to a secluded area under the guise of riding his bicycle and sexually assaulted her.
- Noella testified that Ulgasan threatened her to remain silent about the incidents.
- Ulgasan denied the allegations, claiming they were fabricated due to a dispute with Noella's brother over a bicycle.
- He presented an alibi, asserting he was at home during the alleged incidents.
- The trial court found Noella's testimony credible and dismissed Ulgasan's defense.
- Ulgasan was sentenced to reclusion perpetua for each count and ordered to pay civil indemnity and moral damages to Noella.
Issue:
- (Unlock)
Ruling:
- The Supreme Court upheld the Regional Trial Court's decision, finding Ulgasan guilty beyond reasonable doubt of three counts of statutory rape.
- The Court affirmed the credibility of Noella's testimony and ruled that the lack of a police blotter entry and medical certificate did not undermine the occurrence of the crimes.
- Ulgasan's alibi was dismissed due to the victim's positive identification.
- He was sentenced to ...(Unlock)
Ratio:
- The Supreme Court highlighted the significance of the victim's credibility, noting that trial courts' assessments of witness credibility are typically upheld on appeal.
- A credible witness provides a clear and consistent account, which Noella demonstrated.
- The absence of a police blotter entry does not definitively indicate that the rapes did not occur, as su...continue reading
Case Digest (G.R. No. 131824-26)
Facts:
In the case of People of the Philippines vs. Federico Ulgasan y Salem, decided on July 11, 2000, the accused, Federico Ulgasan, was charged with three counts of statutory rape against an 11-year-old girl named Noella Garolacan. The incidents took place on February 15, March 6, and April 6, 1997, in Bacolod City, Philippines. During the trial, it was established that Ulgasan lured Noella to ride his bicycle and took her to a secluded area where he sexually assaulted her. Noella provided a detailed account of the assaults, stating that Ulgasan threatened her and coerced her into silence, warning her not to tell anyone about the incidents. In his defense, Ulgasan denied the charges, claiming they were fabricated as retaliation for his refusal to lend his bicycle to Noella's brother. He presented an alibi, asserting that he was at home during the times of the alleged assaults. However, the trial court found Noella's testimony credible and consistent, while dismissing the defense's arguments regarding the lack of a police blotter entry and medical certificate as insufficient to undermine the prosecution's case. Consequently, the trial court sentenced Ulgasan to reclusion perpetua for each count and ordered him to pay civil indemnity and moral damages to Noella.
Issue:
- Was the testimony of the victim, Noella Garolacan, credible enough to support the conviction of Fede...