Title
People vs. Umali y Espina
Case
G.R. No. 76530
Decision Date
Mar 1, 1995
In this case, Redentor Umali was convicted of raping Corazon Maniquiz, a third-year high school student. Corazon testified that Redentor sexually abused her while she was staying at her cousin's house, and she positively identified him as the perpetrator. The court affirmed Redentor's conviction, ruling that the minor inconsistencies in Corazon's testimony did not affect her credibility. The court also rejected Redentor's defense of alibi, as he failed to prove that it was physically impossible for him to have reached the location of the crime after work. The court emphasized the importance of the victim's credibility in rape cases and held that minor inconsistencies should not be used to discredit the victim's account.
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Case Digest (G.R. No. 76530)

Facts:

  • Redentor Umali y Espina was convicted of raping Corazon Maniquiz, a third-year high school student.
  • The incident occurred on June 20, 1985, in Bulacan, at the house of Corazon's cousin, Susana Umali.
  • Susana had asked Corazon to stay overnight, claiming her husband, Redentor, was in Manila.
  • Corazon went to bed at 9 PM but was awakened at midnight to find Redentor on top of her, naked, and herself without underwear.
  • Despite her resistance and pleas for help, Redentor raped her while pressing a knife to her neck.
  • Corazon kept the incident secret until August 19, 1985, when she told her mother after noticing signs of pregnancy.
  • They reported the crime to the police and obtained a medical examination from the NBI, which confirmed evidence of sexual intercourse.
  • Redentor was charged and convicted of rape by the Regional Trial Court of Malolos, Bulacan, on October 3, 1986, and sentenced to reclusion perpetua.
  • He appealed the decision, citing inconsistencies in Corazon's testimony and the improbability of the rape scenario.

Issue:

  • (Unlock)

Ruling:

  1. The court ruled that the minor inconsistencies in Corazon's testimony did not affect her overall credibility.
  2. The court rejected Redentor Umali's defense of alibi, as he failed to prove it was physically impossible for him to be at the crime scene.
  3. The court found it credibl...(Unlock)

Ratio:

  1. The court emphasized that minor inconsistencies in a witness's testimony are to be expected and do not necessarily undermine their credibility. Corazon's clear and direct account of the rape and her positive identification of Redentor as the perpetrator were deemed credible. The inconsistencies regarding the dates she reported the crime and underwent a medical examination were considered minor and collateral details that did not detract from the substance of her testimony.
  2. For an alibi to be successful, it must be proven that the accused was at another place at the time of the crime and that it was physically impossible for them to be at the crime scene. Redentor's work schedule at the Philippine General Hospital in Manila ended at 2:30 PM, and the crime occurred around midnight in Bulacan, a two to three-hour drive awa...continue reading

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