Case Summary (G.R. No. 147671)
Procedural Background
The prosecution initiated its case by filing an information on March 5, 1997, alleging that, on the night of December 8, 1996, both accused-appellants conspired to commit rape and subsequently killed the victim. Rico Dolim testified that he last saw Candy that day as she left to collect basketball bets, and when she failed to return by evening, he searched for her. The lifeless body of Candy was discovered on December 12, 1996, with indications of sexual assault, prompting the family to seek police assistance.
Testimonies and Evidence Presented
The prosecution presented six witnesses, including Rico Dolim, who established a connection between the accused-appellants and the victim. Other witnesses included family members and local individuals, such as Aurea Cabagtong, the mother of a co-witness, and various police personnel who participated in the investigation. Key witness Ronnie Cabagtong claimed to be an eyewitness, alleging he saw Mendez raping Candy, further asserting that he overheard threats made by the accused when they visited his house later that evening.
Dr. Santiago Engo performed the autopsy on Candy, revealing she had multiple stab wounds and a lacerated vaginal wound, though he was unable to extract any semen samples due to the state of decomposition of the body. This absence of physical evidence of sexual assault led to significant questions surrounding the credibility of the testimonies.
Defense Argumentation
The defense contended that the prosecution relied heavily on the dubious testimonies of witnesses, especially Ronni Cabagtong, suggesting they were unreliable, inconsistent, and possibly motivated by self-interest. They presented a counter-narrative, asserting that another individual, Randy Gomba, not the accused, was responsible for the crime. Witnesses testifying for the defense spoke of having witnessed an assault involving Gomba, yet this was never sufficiently pursued by the police.
Court Decision
The trial court ruled against the accused, expressing substantial belief in the credibility of the prosecution's witnesses. However, upon appeal, the higher court meticulously analyzed the evidence presented. Notably, it highlighted various inconsistencies in testimonies, including the dubious ability of witnesses to identify the accused in adverse conditions, including heavy rain and darkness.
The appellate court concluded that the prosecution had failed to establish the guilt of the accused beyond a reasonable doubt. Key findings included the lack of corroborating evidence and significant lapses in police procedure, particularly regarding arrests made
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Case Overview
- This case involves an appeal from the decision of the Regional Trial Court, Branch 22, Laoang, Northern Samar, which found accused-appellants Renante Mendez and Baby Cabagtong guilty of rape with homicide.
- The trial court sentenced each of the accused to death and ordered them to indemnify the heirs of the victim, Candy Dolim, in the amount of P100,000.00.
- The Supreme Court reversed the trial court's decision and acquitted the accused-appellants on the basis of reasonable doubt.
Procedural History
- The prosecution commenced with the filing of an information by Prosecutor Napoleon C. Lagrimas on March 5, 1997, alleging that on December 8, 1996, the accused-appellants conspired to rape and murder Candy Dolim.
- The accused-appellants pleaded not guilty, and trial ensued with six witnesses being presented by the prosecution.
Key Witnesses and Testimonies
Rico Dolim (Victim's Father):
- Described the circumstances of Candy's disappearance on December 8, 1996, and the discovery of her body on December 12.
- Noted that Candy was found in a disturbed state, with her clothing disheveled and multiple wounds on her body.
Aurea Cabagtong (Witness and Mother of Ronnie):
- Claimed to have seen accused-appellants washing their clothes to remove bloodstains and that they sought shelter at her house on the night of the crime.
Ronnie Cabagtong (Eyewitness):
- Testified that he witnessed Renante Mendez raping Candy while Baby Cabagtong held her hands.
- Claimed to have recognized the accused due to a lantern's light despite the d