Case Summary (G.R. No. 194362)
Charges and Proceedings
The informations, dated February 17, 1998, allege that Marquez, with lewd design and by means of force and intimidation, had carnal knowledge of Maria Cristina against her will. Upon arraignment, Marquez pleaded not guilty, and the trial proceeded. The trial court found Marquez guilty beyond a reasonable doubt, sentencing him to death for each count and ordering him to pay moral damages of P150,000.00 to the victim.
Evidence and Testimonies
The prosecution presented testimonies indicating that Marquez forcibly dragged Maria Cristina from her home to a nearby banana plantation multiple times in October 1997, where he raped her. Maria Cristina eventually confided to her mother on January 8, 1998, leading to a medical examination; findings included an old hymenal laceration consistent with forced sexual intercourse. In defense, Marquez asserted an alibi, claiming he was at work during the time of the alleged incidents.
Allegation of Indefinite Date
Marquez contended that the failure of the prosecution to specify exact dates in the informations constituted a violation of his rights, arguing that the phrase "on or about the month of October, 1997" deprived him of an adequate opportunity to prepare his defense. However, the court noted that objections to the specifics of the time should have been raised via a motion for a bill of particulars before arraignment, which Marquez did not pursue.
Court's Ruling on Timeliness of Allegations
The court ruled that the exact date is not an essential element in rape cases based on established jurisprudence. It emphasized that as long as the informations sufficiently charged Marquez with the crime and the evidence during trial substantiated the claims, the alleged failure regarding specific dates did not warrant overturning the conviction.
Evaluation of Alibi Defense
Marquez’s defense of alibi was deemed insufficient. He failed to prove that it was physically impossible for him to be at the scene of the crime. The court pointed out that while his workplace was proximate to the victim's residence, his claims regarding muddy conditions of the road were not persuasive, especially since it was confirmed that there was no rain during the period in question.
Assessment of Credibility
The court scrutinized Maria Cristina's testimony, which was detailed and credible, finding it consistent and compelling. The court maintained that the victim's willingness to testify and the lack of any motive to fabricate her claims significantly bolstered her credibility.
Legal Implications and Penalties
The trial court sentenced Marquez to death as the charges involved the rape of a minor, relying on provisions from Republic Act No. 7659. However, the Supreme Court held that the prosecution failed to provide adequate evidence
...continue readingCase Syllabus (G.R. No. 194362)
Case Overview
- The case involves the conviction of Willy Marquez for three counts of rape against five-year-old Maria Cristina Agustin.
- The offenses occurred in October 1997 in Brgy. Bacayao, Municipality of Guimba, Province of Nueva Ecija, Philippines.
- The trial court found Marquez guilty beyond reasonable doubt, sentencing him to death for each count and ordering him to pay P150,000.00 as moral damages.
Facts of the Case
- The prosecution presented evidence that, in October 1997, Marquez forcibly took Maria Cristina from her house to a nearby banana plantation.
- On three separate occasions, he undressed her, assaulted her sexually, and threatened her to keep quiet about the incidents.
- The victim disclosed the assaults to her mother on January 8, 1998, leading to a medical examination which revealed an old healed hymenal laceration.
Defense Argument
- Marquez denied committing the rapes, claiming he was at work during the day throughout October 1997.
- He argued that the prosecution failed to provide precise dates for the alleged rapes, asserting that this lack of specificity constituted a procedural infirmity.
Court's Analysis of Defense Claims
- The Court stated that the precise date of the rape is not an essential element of the crime.
- The accused did not request a bill of particulars b