Title
People vs. Luneta
Case
G.R. No. L-840
Decision Date
Jan 12, 1948
In 1946, Cesar Luneta and Dominador robbed and raped Leon Gonzales and Segunda Fuentes in Capiz. Luneta was convicted; the Supreme Court upheld the verdict, adjusting the penalty but rejecting the uninhabited-place aggravator.

Case Summary (G.R. No. L-840)

Facts of the Case

On the afternoon of January 5, 1946, Leon Gonzales and his wife, Segunda Fuentes, were walking in a secluded area when they were accosted by the appellant, Cesar Luneta, and an accomplice named Dominador, who remains at large. Both men were armed and posed as members of the military. They proceeded to assault Leon Gonzales, physically attacking him, while the appellant intimidated the couple at gunpoint. Dominador ordered the spouses to undress and later initiated an assault on Segunda Fuentes while Leon managed to flee. Subsequently, Luneta also sexually assaulted Segunda Fuentes. The culprits fled the scene with the couple's clothing and other valuables worth P375. The spouses later reported the crime to the police, leading to the identification of the appellant.

Legal Proceedings and Appellant's Defense

Cesar Luneta was tried and found guilty of robbery with rape, receiving an indeterminate prison sentence ranging from 8 years and 1 day to 14 years, 8 months and 1 day, along with an order to indemnify the offended parties. Luneta's defense was primarily a denial of the allegations, claiming to have been at a relative's house at the time of the incident.

Evaluation of Evidence

The Supreme Court upheld the trial court's decision, emphasizing the credibility of the offended parties. Their swift reporting of the incident and the prompt identification of the appellant were pivotal in supporting their testimony. The high court noted the absence of any motive for them to fabricate their testimony against Luneta. The prosecution's evidence was consistent with the spouses’ accounts, suggesting no discrepancy or fault in their statements.

Consideration of Aggravating Circumstances

The court dismissed the Solicitor General's argument that the crime was aggravated by the fact that it took place in an uninhabited area. The evidence did not support that the location was chosen deliberately to facilitate the crime, and there was no proof that the assailants had sought out the victims.

Applicable Law and Sentencing

The crime of robbery with rape is governed by Article 294, paragraph 2, of the Revised Penal Code, which prescribes a penalty of reclusion temporal in its medium period to reclusion perpetua. Due t

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