Title
People vs. Lozano
Case
G.R. No. 126149
Decision Date
Dec 7, 2001
A 12-year-old girl was raped by Dionisio Lozano, who threatened her family. Despite his alibi, the Supreme Court upheld his conviction, affirming the victim's credible testimony and imposing reclusion perpetua.

Case Summary (G.R. No. 126149)

Incident Overview

The accusation against Dionisio Lozano arose from an incident that occurred on the morning of August 29, 1993. The Information charged him with the crime of rape, specifically that he unlawfully had carnal knowledge of Cynthia by means of force, intimidation, and against her will and consent. Following the arraignment, Lozano pled not guilty.

Trial and Verdict

After trial proceedings, the Regional Trial Court convicted Lozano, sentencing him to reclusion perpetua and imposing monetary compensation to the victim, totaling PHP 150,000 (PHP 50,000 for civil indemnity, PHP 50,000 for moral damages, and an additional PHP 50,000 for victim's counsel, later contested).

Victim's Testimony

Cynthia testified about the traumatic encounter, describing how Lozano threatened her with harm to her family to prevent her from shouting. Her detailed account illustrated the incident, noting the physical pain she endured. The court considered her testimony credible, highlighting her fear and vulnerability, especially given her difficult home circumstances.

Application of Law

Rape under Philippine law, as defined in Article 335 of the Revised Penal Code, includes having carnal knowledge of a woman under specific circumstances, including force or intimidation or when the victim is under twelve years of age. The prosecution was required to establish that the act occurred without Cynthia's consent, which the evidence demonstrated through her testimony and corroborating witness accounts.

Defense Argument

Lozano’s defense comprised a denial of the allegations and an alibi indicating he was shoveling gravel nearby at the time of the crime. However, the appellate court found this defense weak against the clear testimony provided by the victim and the corroborating evidence from other witnesses.

Assessment of Evidence

The absence of sperm in the victim's examination and the description of lacerations were challenged by Lozano as basis for dismissal of the charges. However, the court held that the legal definition of rape does not depend solely on visible physical evidence but rather on the victim's testimony about the assault and the context of intimidation involved.

Credibility of Witnesses

The trial court’s assessment of witness credibility played a pivotal role in affirming the conviction. The supporting testimony from Cynthia's granduncle, who witnessed Lozano shortly after the incident, contributed to the prosecution’s case. The court underscored that differing human reactions in crises do not diminish the validity of a witness's account.

Final Ruling and Modifications

The appellate court affirmed the findings of the lower court

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