Title
People vs. Vaynaco
Case
G.R. No. 126286
Decision Date
Mar 22, 1999
Credible testimony from a mentally disturbed victim can outweigh alibi defenses, underscoring its critical role in rape convictions.
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Case Digest (G.R. No. 126286)

Facts:

  • The case involves the People of the Philippines as the plaintiff-appellee against Roger Vaynaco, Roneo Tabones, and Allan Cajipe, the accused-appellants.
  • The events occurred on September 26, 1994, in Tacloban City, Philippines.
  • May Anne Gabrito, a 15-year-old student from Leyte Colleges, was returning home from Gaisano Shopping Center when she met seven college students from Divine Word University.
  • The students invited her to Sandy Beach Resort, where they consumed alcohol together.
  • Later that evening, the seven students gang-raped her in a cottage at the resort.
  • After the assault, May Anne was forcibly taken by eleven other teenagers to Costa Brava beach resort, where she was raped again by multiple assailants.
  • The ordeal lasted from 7:00 PM until around 4:00 AM the next day.
  • May Anne had a history of mental health issues, including a mood disorder, major depression, and schizo-affective disorder, affecting her decision-making.
  • On November 29, 1994, the City Prosecutor of Tacloban City filed four informations against the accused for the rapes.
  • The trial court convicted Vaynaco, Tabones, and Cajipe, sentencing each to three penalties of reclusion perpetua and ordering them to pay P150,000.00 in moral damages.
  • The accused appealed, claiming insufficient evidence and violation of their right to due process.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the trial court's decision, finding no reversible error in the conviction.
  • The Court ruled that the evidence, particularly the victim's testimony, was sufficient to establish guilt beyond a reasonable doubt.
  • The Court held that the trial ju...(Unlock)

Ratio:

  • The Court emphasized that a victim's testimony, even from a mentally disturbed individual, can still be credible and sufficient for conviction.
  • A victim's declaration of rape is a strong basis for conviction if it meets the credibility test.
  • The trial court's assessment of the victim's testimony was given the highest respect, corroborated by medical evidence showing spermatozoa and injuri...continue reading

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