Case Summary (G.R. No. 252578)
Procedural History
Petronilo Abapo was charged in two criminal cases, Criminal Case No. 133(90) and Criminal Case No. 136(90), under Article 335 of the Revised Penal Code. Upon being arraigned, he pleaded not guilty to both charges. A joint trial was held where the testimonies and evidence were presented, leading to the trial court’s decision finding him guilty of both counts of rape.
Findings of the Trial Court
The trial court imposed a penalty of reclusion perpetua for each count of rape. Moreover, the court ordered Abapo to pay various damages to the victims, including moral damages, compensatory damages, and litigation costs. The trial court's findings were heavily based on the credibility of the testimonies provided by the complainants.
Appellant’s Arguments
Abapo appealed the decision, alleging several errors by the trial court. His arguments included claims that the charges were fabricated, that he had been illegally arrested, that there was a conspiracy against him involving the complainants and their relatives, that evidence against him was planted, and that the credibility of the complainants was compromised due to certain inconsistencies in their testimonies.
Evaluation of Witness Credibility
The Court highlighted the principle that the credibility of witnesses is crucial in cases of sexual assault, emphasizing the weight given to trial court findings. The testimonies of both Merlyn and Cherry Lyn were considered credible. The court noted that inconsistencies in their testimony did not detract from their overall reliability.
Evidence Proving Rape
The court established that both Merlyn and Cherry Lyn had experienced sexual intercourse forcibly and against their will. Testimonies indicated that they were threatened by Abapo during the assaults. Medical examinations confirmed that both minors were no longer in a state of virginity, albeit revealing no physical injuries, which is common in statutory rape cases.
Dismissal of Fabrication Claims
The Court dismissed Abapo’s assertion that the charges were fabricated due to alleged motivations linked to familial jealousy. It reasoned that the trauma of undergoing a rape trial would be too great for minors to fabricate accusations purely out of revenge or jealousy.
Legality of Arrest and Illegality of Evidence
Abapo claimed his arrest was unlawful and that ev
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Case Overview
- This case involves an appeal from the decision of the Regional Trial Court of Davao del Sur, Branch 19, which found accused-appellant Petronilo Abapo guilty of two counts of rape.
- The rapes occurred in January 1989 and September/October 1989 against two minor victims, Merlyn Navalon and Cherry Lyn Navalon.
- The appellant was sentenced to two life sentences, alongside various monetary awards to the victims.
Charges and Allegations
Criminal Case No. 133(90):
- Allegation of rape against Merlyn Navalon, committed on January 1989 in Digos, Davao del Sur.
- The accused allegedly threatened Merlyn with death while she was asleep, leading to forcible carnal knowledge.
Criminal Case No. 136(90):
- Allegation of rape against Cherry Lyn Navalon, committed in late September or early October 1989, also in Digos, Davao del Sur.
- The accused allegedly used force and intimidation, as Cherry Lyn was only 11 years old at the time of the incident.
Trial and Verdict
- The accused pleaded not guilty during the arraignment, leading to a joint trial for both cases.
- The trial court ultimately found Petronilo Abapo guilty of both counts of rape and imposed the following penalties:
- Criminal Case No. 133(90):
- Reclusion perpetua (life imprisonment) and various damages to Merlyn.
- Criminal Case No. 136(90):
- Reclusion perpetua (life imprisonment) and similar damages to Cherry Lyn.
- Criminal Case No. 133(90):
Appellant's Assignments of Error
- Fabrication Claims: The appellant claimed the allegations were fabrications by the victims and th