Case Summary (G.R. No. 22442)
Procedural History
Anastacia de Jesus lodged her complaint on October 8, 1974, in the Municipal Court of Pulilan, Bulacan. Judge Alfredo V. Granados conducted a preliminary investigation and subsequently ordered the arrest of the accused after amending the complaint. The case was elevated to the Court of First Instance (CFI) of Bulacan, leading to the filing of an information for forcible abduction with rape against Gorospe and Bulanadi. The trial commenced on October 15, 1975, in the absence of the accused, resulting in their conviction.
Factual Background
Anastacia de Jesus testified that on the morning of September 25, 1974, she was abducted by the accused when Bulanadi used a handkerchief to impair her consciousness. After regaining consciousness, she found herself in a nipa hut with Gorospe and Bulanadi, who then sexually assaulted her multiple times over the following nine days while being guarded by Oscar Alvaran. Anastacia eventually managed to escape and report her ordeal to local authorities.
Testimony and Evidence
Anastacia's physical examination indicated that she suffered from injuries consistent with sexual assault. The medical exam corroborated her claims of previous lacerations and suggested the use of force during the assaults. Moreover, her testimony was supported by that of Gerardo Fajardo, who had been initially named as a co-accused but later became a state witness. He provided consistent details about the events, notwithstanding the attempts by the defense to undermine his credibility.
Appellants' Arguments
The appellants raised four assignments of error, claiming improper venue for the trial, authority issues regarding the presiding judge, the admission of Fajardo's incomplete testimony, and disputes regarding the credibility of witnesses and their own innocence. They sought to argue that the initial abduction and the crimes occurred outside the jurisdiction of Bulacan and emphasized the supposed absence of credible evidence against them.
Legal Interpretations
The court addressed the procedural error claims, citing legal precedents permitting abduction charges to be tried in jurisdictions where any elements of the crime occurred. They noted that abduction is a continuing offense, making it reasonable for the Municipal Court of Pulilan to act in the interests of jurisdiction. Furthermore, the court clarified that jurisdiction lies with the court system and not individual judges. The trial court held that despite the incomplete cross-examination of Fajardo due to his delinquency, the testimony was still admissible as it provided substantial corroboration for the prosecution's case.
Evaluating Witness Credibility
In evaluating witness credibility, the court indicated a preference for the testimony of Anastacia de Jesus, given her consistent recounting of events despite minor inconsistencies attributed to her age and emotional trauma. Th
...continue readingCase Syllabus (G.R. No. 22442)
Case Overview
- Case Citation: 214 Phil. 201 EN BANC
- G.R. No.: L-51513
- Date of Decision: May 15, 1984
- Parties: The People of the Philippines (Plaintiff-Appellee) vs. Feliciano Gorospe and Rufino Bulanadi (Accused-Appellants)
- Nature of Case: Forcible abduction with rape
Background of the Case
- Filing of Complaint: Anastacia de Jesus filed a verified complaint on October 8, 1974, against Gorospe, Bulanadi, and Gerardo Fajardo for forcible abduction with rape.
- Date of Alleged Crime: The alleged crime occurred on September 25, 1974.
- Initial Proceedings: The case began in the Municipal Court of Pulilan, Bulacan, where Judge Alfredo V. Granados conducted a preliminary investigation.
- Amendments to the Complaint: The complaint was amended on October 25, 1974, dropping Fajardo and including Oscar Alvaran as an accused.
- Arrest and Bail: Arrest warrants were issued on November 18, 1974, and bail was set at P15,000.00 for each accused.
Trial Proceedings
- Trial Start Date: Trial commenced on October 15, 1975, with both Gorospe and Bulanadi absent.
- Change of Judges: Judge Fidel P. Purisima took over the case but inhibited himself from deciding due to a familial connection to Judge Granados.
- Final Decision Maker: Judge Jesus R. de Vega rendered the final judgment, finding Gorospe and Bulanadi guilty of rape.
Judgment Details
- Sentences: Each accused was sentenced to two perpetual penalties of reclusion perpetua and ordered to pay P40,000.00 in damages to Anastacia de Jesus.
- Core Findings: The court determined that both accused were guilty beyond reasonable doubt and responsible for the acts committed by one another due to conspiracy.
Facts of the Case
- Victim’