Case Digest (G.R. No. 255389)
Facts:
The People of the Philippines v. Carlo Diega y Zapico, G.R. No. 255389, September 14, 2021, the Supreme Court First Division, Lopez, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the accused-appellant is Carlo Diega y Zapico, charged along with three unnamed co-perpetrators ("John Does").On April 14, 2013, AAA (a 12-year-old girl, name withheld) and her companion JJJ were accosted by Ismael, who brought AAA to a drinking session where she met Obat (alias), Kalbo (alias), and Carlo. After drinking and becoming drowsy, AAA was taken to a vacant lot, where she alleged that Carlo removed her garments, that others held her legs and hands, that someone spat on her genitalia, and that Carlo then had carnal knowledge of her; thereafter the three others took turns in raping her. AAA reported the incident to barangay authorities and police on April 15, 2013; medico-legal examination (Medico-Legal Report No. R-13-359 dated April 16, 2013) showed recent blunt penetrating trauma to the genitalia consistent with the account.
Carlo pleaded not guilty and claimed denial and alibi: he testified that he had gone home twice that night and was later apprehended at home. Trial before the Regional Trial Court (RTC), Criminal Case No. C-89752, resulted in conviction on April 16, 2018; the RTC found AAA credible, concluded that Carlo and his three companions had conspired, and sentenced Carlo to reclusion perpetua with awards of civil indemnity (P75,000), moral damages (P75,000) and exemplary damages (P50,000). Carlo appealed to the Court of Appeals in CA-G.R. CR HC No. 11398.
On June 29, 2020, the Court of Appeals affirmed the RTC's conviction but modified awards of damages upward to P100,000 each for civil indemnity, moral and exemplary damages, with 6% interest from finality. Carlo sought further recourse to ...(Pro-only)
Issues:
- Was the testimony of the prosecution witness AAA credible and sufficient to sustain Carlo’s conviction for rape?
- Is Carlo criminally liable for the rapes committed by his co-conspirators although they were unidentified or at large?
- Can Carlo’s uncorroborated denial and alibi overcome the prosecution’s evidence?
- What penalties and damages shou...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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