Title
People vs. Golidan y Coto-Ong
Case
G.R. No. 205307
Decision Date
Jan 11, 2018
A 1995 Baguio crime involving rape, homicide, and frustrated murder; accused convicted based on a child witness's testimony despite cerebral palsy, forensic evidence, and rejected alibis.

Case Summary (G.R. No. 175578)

Case Background

The case revolves around the gruesome events that took place on January 20, 1995, in Baguio City, where the accused, in conspiracy, committed the crimes of rape with homicide, murder, and frustrated murder. The victims included AAA, who was raped and killed, and BBB, a one-year-old infant murdered, while CCC, a ten-year-old girl, was seriously injured but survived.

Criminal Charges and Proceedings

The prosecution brought forward three separate informations filed by Assistant City Prosecutor Elmer M. Sagsago against the accused. The Regional Trial Court (RTC) found them guilty of the charges based largely on the testimony of Cherry Mae, the only survivor, alongside forensic evidence and corroborative witness accounts.

Evidence Presented

The prosecution presented various testimonies establishing the facts surrounding the crime. Jennyline Aniban, mother of the child victims, discovered the horrific scene upon returning home. Autopsy reports confirmed the violent nature of the crimes, with AAA showing signs of brutal assault and rape, while BBB's death was attributed to severe head trauma.

Competency of Witness

One of the core issues was the competency of Cherry Mae as a witness, given her disabilities due to cerebral palsy. The Court of Appeals upheld her competency based on expert testimonies stating that despite her condition, she could perceive and communicate effectively. This was critical in establishing the credibility of her identifications of the accused.

Appeal and Conviction

The RTC's decision, affirming the convictions of the accused, was later appealed to the Court of Appeals, which modified some penalties but upheld their convictions. The appellants asserted that Cherry Mae's testimony was insufficient due to her medical condition and that they were not at the crime scene, but the appellate court found substantial evidence supporting the prosecution’s case.

Conspiracy and Identification

The court ruled that the conspiracy among the accused was established through their coordinated actions during the crime. The absence of defense evidence to substantiate alibis further strengthened the prosecution’s claims. Cherry Mae's failure to identify the accused promptly was deemed understandable given her trauma from the attacks.

Final Rulings and Modifications

The Supreme Court ultimately affirmed the Court of Appeals' decision while modifying the amounts of

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