Case Summary (G.R. No. 134774)
Charges and Legal Proceedings
The information filed against Manuel Lopez on January 10, 1994, charged him with rape under Article 335 of the Revised Penal Code. Following his arraignment on August 31, 1994, where he pleaded not guilty, the trial commenced. The prosecution presented four witnesses, including the victim, her mother, and a municipal health officer who conducted a medical examination. The defense, on the other hand, called upon the accused himself and a relative to testify.
Evidence Presented
Dr. Henry Moreno, the municipal health officer, testified that during the medical examination of Jessica on October 22, 1993, he found evidence supporting the allegation of rape, including a torn hymen and positive results for sperm. Josefina Liz, the victim's mother, recounted how she brought her daughter to the house of a quack doctor for treatment and was subsequently informed by Jessica about the alleged rape. Jessica testified in detail about the incident, describing how she was attacked by Manuel Lopez, whom she recognized and had previously interacted with during her stay at the house.
Defendant’s Testimony
Manuel Lopez denied the charges, asserting that he was present in the house at the time of the alleged rape but was asleep with others. He claimed multiple locations within the house for his location during the incident, which introduced inconsistencies in his account. He also contended that the lack of physical divisions in the crowded house made it improbable for the assault to occur unnoticed.
Trial Court Decision
The Regional Trial Court, after careful consideration of the evidence, convicted Manuel Lopez of rape on April 14, 1998, sentencing him to reclusion perpetua and ordering him to pay P50,000 in indemnity to the victim. The trial court found the testimony of Jessica credible and sufficient to establish the guilt of the accused beyond reasonable doubt.
Appeal and Credibility of Testimony
On appeal, Lopez contested the trial court's decision primarily on grounds of alleged witness credibility. He argued that Jessica's testimony lacked the semblance of reality given the surroundings. However, the Office of the Solicitor General countered this argument by emphasizing Jessica's clear recollection of the events, voluntary participation in the medical examination, and perseverance in seeking justice. The appellate court recognized the principle that the trial court's findings on witness credibility are generally upheld unless substantial facts are overlooked.
Ruling on Alibi and Final Judgment
The appellate court rejected the alibi defense, noting Lopez failed to prove physical impossibility of his presence at the crime scene. It affirmed that rape can occur even in crowde
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Case Background
- The case involves an appeal from the decision dated April 14, 1998, by the Regional Trial Court of Daet, Camarines Norte, Branch 38.
- The appellant, Manuel Lopez @ Awe, was convicted of rape under Criminal Case No. 8108 and sentenced to reclusion perpetua.
- The court also ordered Lopez to indemnify the victim, Jessica B. Liz, in the amount of P50,000.
Charge of Rape
- The information filed on January 10, 1994, charged Manuel Lopez with rape as defined under Article 335 of the Revised Penal Code.
- The incident allegedly occurred on October 16, 1993, at around 10:00 PM in Brgy. San Vicente, Santa Elena, Camarines Norte.
- The prosecution alleged that Lopez, while armed with a bladed weapon and using violence and intimidation, had carnal knowledge of Jessica B. Liz, a minor aged 9.
Arraignment and Trial
- Manuel Lopez was arraigned on August 31, 1994, and pleaded not guilty.
- The trial saw testimonies from several witnesses including Dr. Henry Moreno, Josefina Liz (mother of the victim), Jessica Liz (the victim), and SPO3 Benjamin Torres.
Prosecution's Evidence
- Dr. Henry Moreno: Conducted a medical examination on Jessica, noting genital findings consistent with trauma, including a hymenal tear and positive but dead sperm, indicating penetration.
- Josefina Liz: Testified that she took Jessica to the house of Lope Lopez for treatment and that Jessica disclosed the rape incident to her shortly after it occurred.
- Jessica Liz: Provided a detailed account of the assault, identifying Manue