Title
People vs. Maguad y Nicor
Case
G.R. No. 116514
Decision Date
Mar 13, 1998
A 1991 rape-murder case in La Carlota City, Philippines, where Nelson Llonor was convicted based on witness testimony, circumstantial evidence, and possession of the murder weapon, despite his alibi defense. The Supreme Court upheld his reclusion perpetua sentence and damages.

Case Summary (G.R. No. 116514)

Charges and Allegations

The information filed against the accused on August 14, 1991, alleged that they, armed with knives, raped Josephine Pelayo, subsequently murdered her by stabbing her multiple times, and stole her belongings. The prosecution emphasized the aggravating circumstances of superior strength and the commission of the crime in an uninhabited place.

Testimonies Presented

Two key witnesses, Nestor Samban and Ireneo Cabuguason, provided testimonies regarding the incident. Samban testified that he saw Llonor and Maguad with the victim, while Cabuguason recounted seeing Llonor committing the act of rape, holding a knife to Pelayo's neck. The police officer, Patrolman Remegio Reloj, and Dr. Edwin Jayme provided crucial evidence, including the discovery of Pelayo's body and the forensic findings supporting the prosecution's case.

Evaluation of Witness Credibility

The trial court evaluated Samban's testimony and found significant inconsistencies, ultimately deeming it unreliable. In contrast, it found Cabuguason's account credible and corroborated by physical evidence, such as the knife used in the crime, matching the wounds found on the victim's body.

Court Decision and Rulings

The trial court acquitted Maguad but found Llonor guilty of rape with homicide, imposing a sentence of reclusion perpetua and damages amounting to P100,000. The court deemed the crime as a Special Complex crime of rape with homicide, emphasizing that proof of robbery was secondary to the intent to commit rape.

Appellate Review

In appealing the trial court's decision, Llonor contested the credibility of Cabuguason's testimony and argued that his alibi should suffice for acquittal. However, the appellate court discounted these claims, reaffirming Cabuguason's positive identification of Llonor as the perpetrator and the overall weight of the evidence against him.

Evidence and Standards of Conviction

The appellate court underscored that for an alibi to be credible, it must establish a physical impossibility for the accused to be present at the crime sce

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