Case Digest (G.R. No. 137649)
Facts:
The People of the Philippines v. Rodolfo Villadares, G.R. No. 137649, March 08, 2001, the Supreme Court Third Division, Gonzaga-Reyes, J., writing for the Court.
The accused-appellant, Rodolfo Villadares, was charged by Information with rape for an incident alleged to have occurred on January 20, 1996 in Taguig. The complaining witness was Eliza Sabanal, then about twelve years old. The Information alleged that Villadares, “with lewd designs and by means of force, threats, violence and intimidation,” had carnal knowledge of Eliza against her will.
On March 13, 1997 Villadares pleaded not guilty and trial proceeded before Branch 166 of the Regional Trial Court (RTC) of Pasig City. The prosecution presented the testimony of Eliza, her sister Emma, and their mother Rosa, together with a medico-legal report by Dr. Jesusa Vergara (PNP Crime Laboratory) dated January 31, 1996, which described a healed hymenal laceration and concluded the subject was in a non-virgin state. The statements of Eliza, Emma and Rosa taken at Taguig Police Station on February 3, 1996 were also offered. The Office of the Solicitor General handled the appeal for the People.
Villadares denied the charge and interposed alibi, testifying he left home early that morning to work in Pasig and returned in the late afternoon. His daughter and granddaughter corroborated his alibi. The trial court, however, found the prosecution witnesses credible and convicted Villadares of rape on November 23, 1998, sentencing him to reclusion perpetua and ordering P50,000.00 as moral damages.
Villadares appealed to the Supreme Court assigning as error that the trial court erred in giving full credence to Eliza’s testimony and the medico-legal findings, which he contended were weak and insufficient to sustain conviction beyond reasonable doubt. The appeal was resolved by the Supreme Court Third Division, whose decision was promulgated March 8, 2001 (Gonzaga-Reyes, J., ponente).
Issues:
- Did the trial court err in crediting the testimony of the complaining witness and her sister such that the conviction for rape was not supported beyond reasonable doubt?
- Could the medico-legal report, signed by the examining physician and a police official who did not testify, be given probative value and did its admission materially affect the conviction?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)