Case Summary (G.R. No. L-39763)
Applicable Law
The case is adjudicated under the 1935 Constitution as the decision predates the 1987 Philippine Constitution.
Factual Background
The prosecution established that both Mario and Isidro Andal were involved in the crime of rape against complainant Lucila Buenafe. The incident occurred after the appellants attempted to acquire a pig and sprayer from the Buenafe family but were denied. In retaliation, they forcibly took the complainant to a nearby hill, where the son, Mario, committed the sexual act while Isidro restrained the victim by holding her hands.
Medical Evidence
Medical examination conducted after the incident revealed significant physical injuries indicative of sexual assault. Dr. Gaspar E. Villafane reported contusions, lacerations of the hymen, and that the complainant displayed signs consistent with having been raped, corroborated by the timing of her injuries. The victim was hospitalized for a week due to the severity of her injuries.
Legal Proceedings
The trial court found both appellants guilty based on the victim's testimony and medical evidence. The appellants' defense leaned heavily on the presumption of innocence and questioned the reliability of the complainant's account. The court, however, found that the evidence was more than sufficient to establish guilt beyond a reasonable doubt.
Assessment of Testimonial Evidence
The court considered the testimony of Lucila Buenafe to be credible. Despite attempts by the defense to depict inconsistencies, the cumulative evidence, including her emotional state during testimonies and corroborative marks of trauma, supported her account of the events. The presence of medical findings further reinforced the complainant's narrative against the appellants.
Constitutional Presumption of Innocence
The appellants contended that the prosecution failed to satisfactorily prove guilt beyond a reasonable doubt, invoking the constitutional presumption of innocence. However, the court observed that the medical findings and the victim's consistent recounting of the events significantly outweighed the defense's assertions.
Criminal Liability
Mario Andal was found to have directly perpetrated the rape act while Isidro Andal acted as an accomplice by facili
...continue readingCase Syllabus (G.R. No. L-39763)
Case Background
- The case involves the prosecution and conviction of Mario Andal and Isidro Andal for the crime of rape.
- Mario, the son, committed the sexual act while Isidro, the father, aided him by restraining the victim, a thirteen-year-old girl named Lucila Buenafe.
- The incident occurred on September 5, 1972, in Gapas, Guinayangan, Quezon.
Incident Details
- On the day of the incident, Mario and Isidro approached Lucila's home to inquire about a pig and a sprayer owned by her family.
- After discovering that these items were unavailable, Mario forcibly took Lucila and her brother to a nearby hill.
- They pinned Lucila down; Mario disrobed her and assaulted her while Isidro restrained her hands.
Victim's Testimony
- Lucila testified to being dragged and assaulted, recounting the physical violence inflicted upon her, including being punched and struck in the abdomen, causing her to lose consciousness.
- After regaining consciousness, she experienced pain and immediately sought her father's help, leading to reporting the crime.
Medical Examination
- Lucila underwent a medical examination by Dr. Gaspar E. Villafane, who found significant injuries:
- Contusion on the chest, scratches, and signs of sexual abuse, including lacerations of the hymen.
- The injuries indica