Case Summary (G.R. No. 124916)
Factual Background
The case stems from a complaint filed by Sally Roxas, who, on March 11, 1994, was forcibly abducted and raped by René Almanzor while she was walking to work at a Jollibee restaurant in Makati City. Almanzor allegedly introduced himself as a policeman and threatened her with a gun, forcing her into his vehicle, where he then proceeded to sexually assault her in a secluded area.
Judicial Proceedings
Almanzor was charged with forcible abduction with rape under Criminal Case No. 94-3602. At his arraignment, he pleaded not guilty. The prosecution's evidence relied heavily on Roxas’s testimony, which detailed her abduction and the subsequent assault. Forensic examination confirmed recent sexual activity through medico-legal findings.
Accused's Defense
Almanzor denied the allegations, presenting an alibi that he attended a seminar outside of his home at the time of the incident. He claimed that witnesses corroborated his whereabouts shortly before and after the incident. However, during cross-examination, it was revealed that he faced multiple allegations of similar conduct from other women.
Trial Court Decision
The trial court found Almanzor guilty beyond a reasonable doubt of the crime of forcible abduction with rape. The court imposed the death penalty, citing the use of a deadly weapon and the absence of mitigating circumstances. He was also ordered to pay damages to the victim.
Appeal and Main Arguments
Almanzor appealed on several grounds, primarily contesting the identification of him as the assailant, alleging inconsistencies in the testimonies presented by Roxas, and asserting that the manner of the alleged rape was implausible. He questioned the reliability of the police line-up identification and the absence of immediate physical resistance from Roxas.
Court's Analysis and Ruling
In analyzing the appeal, the Supreme Court underscored the importance of the complainant's credibility in rape cases and ruled that the identification through both the police line-up and in-court testimony was sufficient. The court dismissed the defense's arguments about inconsistencies as inconsequential, clarifying that such factors do not inherently damage the overall credibility of a victim's testimony.
The Supreme Court also noted that the use of a firearm constituted sufficient intimidation, rendering any lack of physical resistance irrelevant to the issue of consent. Ultimately, the Supreme
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Overview of the Case
- The case is an automatic review of the decision by the Regional Trial Court, Branch 66 of Makati City, which found Rene Almanzor y Roxas guilty of forcible abduction with rape.
- The court sentenced the accused to suffer the supreme penalty of death.
- The case stems from a sworn complaint by Sally Roxas, who was abducted and raped on March 11, 1994.
Allegations and Charges
- The Information filed against the accused charged him with forcible abduction with rape, detailing the events of March 11, 1994, in Makati City.
- It was alleged that the accused, claiming to be a Marikina police officer, threatened the complainant with a handgun, forced her into his car, and subsequently raped her at gunpoint in a secluded area.
Prosecution's Evidence
- The prosecution's case primarily relied on the testimony of the complainant, Sally Roxas, who was 17 years old at the time of the incident.
- On the day of the incident, she was on her way to work when the accused stopped his car beside her and introduced himself as a policeman.
- Upon his insistence and under the threat of violence, she entered the car, which he drove past her workplace.
- The accused then ordered her to undress and raped her while threatening her with the gun.
Testimony of the Complainant
- Sally’s testimony included detailed accounts of her abduction, the threats made by the accused, and the sexual assault.
- She described her psychological state during the incident, emphasizing h