Case Digest (G.R. No. 255389) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Carlo Diega y Zapico (G.R. No. 255389, September 14, 2021), the accused-appellant Carlo Diega y Zapico and three unidentified companions (“John Does”) were charged with four counts of Rape under Article 266-A(1)(a) of the Revised Penal Code before the Regional Trial Court (RTC) of Quezon City (Crim. Case No. C-89752). The offended party, AAA, a 12-year-old minor, was walking home with her friend on April 14, 2013, in Quezon City when they were accosted by Ismael, who introduced the victim to Carlo and two other men known as Obat and Kalbo. The group proceeded to drink at a riverbank and then to a nearby vacant lot, where AAA, after being intoxicated, was forcibly stripped and sequentially raped by Carlo and each of his three companions. Despite AAA’s cries and vigorous resistance, no one intervened. The victim reported the crime to the barangay authorities and the police the following morning, and a medico-legal examination confirmed recent blunt Case Digest (G.R. No. 255389) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents and Charges
- On April 14, 2013, AAA, a 12-year-old minor, was accosted by Ismael who introduced her to Obat, Kalbo, and Carlo Diega y Zapico.
- Carlo and three “John Does” were charged under Article 266-A, Paragraph 1(a) of the Revised Penal Code for raping AAA by force and intoxication.
- Incident Details
- After a drinking session at a riverbank and a vacant lot, AAA became dizzy and drowsy; the accused held her limbs, removed her undergarments, and took turns in having carnal knowledge of her against her will.
- AAA resisted by kicking and shouting; she later reported the rape to barangay and police; a medico-legal exam showed recent blunt penetrating trauma to her genitalia.
- Defense of the Accused
- Carlo claimed he left the drinking session at 10:00 p.m., went home to change, returned briefly to warn AAA of people looking for her, then slept at home until barangay officers arrested him the next morning.
- He denied any sexual act, asserted alibi, and argued physical impossibility of his presence throughout the incident.
- Procedural History
- The Regional Trial Court convicted Carlo of rape, found conspiracy with his three companions, imposed reclusion perpetua, and awarded damages (P75,000 for civil indemnity, moral and exemplary each).
- The Court of Appeals affirmed the conviction on June 29, 2020, but increased damages to P100,000 each; Carlo appealed to the Supreme Court (G.R. No. 255389).
Issues:
- Whether AAA’s testimony was credible and sufficient to establish Carlo’s guilt.
- Whether Carlo’s defense of alibi and denial created reasonable doubt.
- Whether the rule on conspiracy renders Carlo liable for the rapes committed by his co-conspirators.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)