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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Case Overview
- The case involves an appeal concerning the conviction of Eduardo Golidan, Francis Nacionales, and Teddy Ogsila for serious crimes, including rape with homicide, murder, and frustrated murder.
- The appeal arises from the April 25, 2012 Decision of the Court of Appeals, which modified the August 18, 1999 Decision of the Regional Trial Court (RTC), Branch 61, Baguio City.
- The RTC found the accused guilty beyond reasonable doubt and sentenced them to severe penalties.
Charges and Facts of the Case
The accused were charged with:
- Rape with Homicide: Involving the victim AAA, where the accused allegedly conspired to rape and kill her.
- Murder: Involving the one-year-old victim BBB, who was killed by the accused.
- Frustrated Murder: Involving the child victim CCC, who was attacked but survived due to timely medical intervention.
The crime was committed on January 20, 1995, in Baguio City.
The victims were AAA (the babysitter), BBB (a one-year-old boy), and CCC (an eight-year-old girl with cerebral palsy).
Circumstances of the crime included brutal physical assault and sexual violence against AAA, and fatal injuries inflicted on BBB.
Evidence Presented
Prosecution Evidence:
- Testimonies from various witnesses, including the mother of the victims, corroborated the timeline and events leading to the discovery of the crime.
- Autopsy results