Case Summary (G.R. No. 102705)
Jurisdiction and Procedural History
The case originated from a complaint filed by Mrs. Elizabeth B. Regino against Doroteo Mejorada in the Municipal Trial Court of Sta. Cruz, Davao del Sur, on October 11, 1988. The Municipal Trial Court found a prima facie case and forwarded the records to the Office of the Provincial Fiscal, which filed an information for rape before the Regional Trial Court (RTC) in Digos on November 8, 1988. The RTC convicted the accused on June 14, 1991, sentencing him to reclusion perpetua but not awarding civil damages due to non-payment of appropriate fees.
Allegations of the Crime
The information alleged that on October 7, 1988, in Sta. Cruz, Davao del Sur, Doroteo Mejorada forcibly dragged Mrs. Regino from her house while armed with a knife, and against her will, forced her to have sexual intercourse. The act was characterized by a disregard for her dignity, as she was a school teacher.
Evidence Presentation
During the trial, the prosecution presented credible testimonies from Mrs. Regino and corroborating witnesses, including Vice Mayor Guido and Dr. Ozoa, who provided medical evidence consistent with sexual assault. Mrs. Regino’s statement outlined the trajectory of events leading up to the assault, detailing the threats made by Mejorada during the incident.
Defense Strategy
The defense relied on alibi and denial, asserting that the accused was at a friend’s house during the time of the crime. However, the testimonies from family members did not adequately establish his whereabouts or counter the prosecution’s case. Additionally, Mejorada’s claim of being framed by another man was not substantiated.
Court's Findings on Credibility
The trial court found the testimonies of the prosecution's witnesses—especially that of Mrs. Regino—to be credible, noting her demeanor and the lack of any ill-motive for her allegations. In contrast, the defense failed to convince the court of Mejorada's innocence. The RTC took special note of the physical evidence presented, including the weapon used and the medical examination results indicating trauma consistent with rape.
Appellant's Arguments
Mejorada's appeal argued that the trial court erred in its judgment by claiming the prosecution lacked clear and convincing evidence. He pointed to weaknesses in Mrs. Regino’s account, but the court found these assertions to be inadequate, particularly in light of the corroborative testimonies and physical evidence.
Legal Conclusions and Ruling
The appellate court affirmed the conviction, emphasizing the trial court's proper assessment of witness credibility and the weight given to corroborative evidence. The court ruled that the accused’s conduct constituted rape under the Revised Penal Code, given the threats made using a deadly weapon during the commission of the crime.
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Case Overview
- On appeal is the decision dated June 14, 1991, from Branch 19 of the Regional Trial Court (RTC) of Davao del Sur in Criminal Case No. 138 (88).
- The accused, Doroteo Mejorada y Sillan, was found guilty of rape and sentenced to reclusion perpetua (life imprisonment) with accessory penalties.
- The RTC did not award damages to the victim, Mrs. Elizabeth B. Regino, due to a lack of evidence showing that filing fees had been paid.
Factual Background
- The complaint was filed by Mrs. Elizabeth B. Regino on October 11, 1988, against the accused in the Municipal Trial Court (MTC) of Sta. Cruz, Davao del Sur.
- The MTC conducted a preliminary examination and found a prima facie case against Mejorada, leading to the transmission of the case to the RTC.
- The Information charged Mejorada with rape, detailing that he forcibly took Mrs. Regino from her house while armed with a knife and had carnal knowledge of her against her will.
Trial Proceedings
- A not guilty plea was entered by the accused on December 12, 1988.
- Prosecution witnesses included Mrs. Regino, her husband, and medical personnel, while the defense called Mejorada, his wife, and daughter.
- On June 20, 1991, the RTC convicted Mejorada of rape, emphasizing the credibility of the prosecution's evidence.
Prosecution's Evidence
- Mrs. Regino testified that on the night of October 7, 1988, she was at home with the a