Title
People vs. Jose y Gomez
Case
G.R. No. L-28232
Decision Date
Feb 6, 1971
Four men abducted and raped a woman in 1967; convicted based on credible testimony and medical evidence, with death penalties imposed.

Case Summary (G.R. No. 110524)

Petitioner and Respondent

Petitioner (in intervention): Filipinas Investment & Finance Corporation (seeks to recover the car).
Respondent: The People of the Philippines (criminal prosecution of the four appellants).

Key Dates

June 26, 1967 – Abduction and successive rapes of the complainant.
June 29, 1967 – Formal complaint filed; first medical examination.
July 1967 – Arrests and extrajudicial statements of the appellants.
October 2, 1967 – Trial court conviction and car confiscation order.
February 6, 1971 – Supreme Court decision.

Applicable Law

1935 Philippine Constitution (Bill of Rights, right to counsel).
Revised Penal Code, Articles 45 (forfeiture of instruments), 48 (penalty for complex crime), 63, 70.
RA 4111 (amendment to Article 335, provision on rape; penalty uplifted to reclusion perpetua or death when multiple assailants or deadly weapon).
Rules of Court, Rules 112–115 (preliminary investigation, arraignment, rights to counsel).

Procedural History

• July 1967 – Basilio Pineda pleads guilty to abduction with rape; judgment reserved pending proof of aggravating circumstances.
• October 1967 – Trial court finds all four guilty of forcible abduction with rape and sentences each to death; dismisses accomplices; orders car confiscation.
• Appeal by Jaime Jose, Pineda, Aquino and automatic review for Canal.
• Intervention by financier seeking to recover the mortgaged car.

Facts of the Case

• At 4:30 a.m., De la Riva was driving home in Quezon City when a convertible with four men tried to bump her Bantam car.
• The driver (Pineda) blocked her gate, dragged her out, and all four men forced her into their car by violence and threats with a Thompson.
• They blindfolded her, drove to Pasay City’s Swanky Hotel, and successively raped her, threatening acid disfigurement.
• After the assault, they ordered her to redress, warned her not to report, and released her near the Free Press Building.
• She reported the crime on June 29, identified each appellant from photographs and in person, and underwent a medico-legal examination revealing multiple bruises and genital injuries.

Evidence Presented

• Complainant’s sworn statements and live testimony—detailed account of abduction, threats, strip-and-rape acts by all four.
• Medico-legal report by Dr. Ernesto Brion—contusions on limbs and genital injuries consistent with violent rape; absence of spermatozoa explained by delay and self-douching.
• Extrajudicial confessions/statements of Jose, Aquino, Canal—admissions of participation and conspiracy, though each attempted partial exculpation.
• Identification by complainant in police custody of each accused.

Defense Theories

• Strip-tease for hire: appellants claimed De la Riva consented to perform for P1,000, with P100 down, thereby negating lewd design and rape.
• Voluntary sexual intercourse: each appellant asserted consensual relations or limited participation.
• Self-infliction or isolation: bruises and injuries attributed to complainant or brief solo encounters.
• Coercion in statements: Jose and Canal alleged police force and supplied details.

Trial Court Decision

• Rejected defense strip-tease theory as “utterly inverisimilar,” undermined by medical findings and commonsense.
• Held complainant’s uncorroborated testimony credible, corroborated by physical evidence and admissions.
• Sentenced all four appellants to death for forcible abduction with rape (complex crime) and ordered confiscation of their car as instrument of the crime.

Issues on Appeal

  1. Sufficiency of evidence on abduction and successive rapes.
  2. Validity of extra-judicial confessions; claim of coercion and lack of counsel.
  3. Applicability of multiple death penalties versus single death penalty.
  4. Lawfulness of car confiscation given registered ownership and intervenor’s chattel mortgage.
  5. Alleged prejudice due to pretrial publicity.

Supreme Court Analysis

• Abduction and rape: unanimous finding of conspiracy and felonious intent by all four; complainant’s detailed testimony and medico-legal report fully establish both crimes.
• Extrajudicial statements: held voluntary, taken in presence of witnesses, sworn before a fiscal; partial exculpations within statements support authenticity.
• Right to counsel: under the 1935 Constitution and Rules 112–115, counsel is guaranteed from arraignment onward; exclusion before arraignment does not render statements inadmissible.
• Multiple death penalties: uph


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