Title
People vs. Olarte
Case
G.R. No. 101793
Decision Date
Dec 7, 1993
Three men broke into a couple's home, raped the wife, robbed them, and threatened their lives. Two accused were convicted based on credible testimonies and unreliable alibis, receiving life imprisonment and indemnity.

Case Summary (G.R. No. 101793)

Criminal Incident and Victim Testimonies

On the morning of August 18, 1990, armed intruders, identifying themselves as members of the New People's Army, entered the Norbe household under the pretense of purchasing alcohol. They were met with resistance from Arlene, but Pedro opened the door to provide water. The intruders forcibly entered, displayed firearms, and restrained Pedro while three of them raped Arlene in the presence of their terrified children. Following the assaults, they stole minor valuables, including cash amounting to P2,755.00, and threatened the couple against reporting the incident.

Identification of the Accused

Days later, Melchor Olarte was arrested for illegal possession of firearms, which led to the identification of both him and Roger Vinearta as the assailants in the Norbe case. Initially, the couple hesitated but ultimately identified Olarte after he was presented to them. Arlene specifically recognized Vinearta based on his appearance when he entered their home. Pedro corroborated this identification, illustrating strong familiarity with both men as regular customers.

Defense by the Accused

During the trial, both appellants offered alibi defenses. Olarte claimed he was drinking at his mother's house a considerable distance away, while Vinearta asserted he was asleep in Talisay, approximately eight and a half kilometers from the scene. However, their alibis were found unconvincing and lacked corroboration.

Trial Court Ruling

Judge Simplicia S. Medina of the Regional Trial Court of Bacolod City convicted both Olarte and Vinearta, sentencing them to reclusion perpetua. This decision was based on the evidence presented, including the positive identification by the Norbe spouses and the absence of credible alibi.

Appeal and Conviction Assessment

In their appeal, the accused argued against the conviction, asserting that the Norbe spouses' testimonies were inconsistent. Despite this, the Court found the spouses credible witnesses with consistent accounts of the crime. It emphasized that the victims had no motive to falsely accuse the accused. Furthermore, the Court dismissed claims regarding procedural irregularities involving Olarte's arrest and torture, stating that such allegations lacked supporting evidence.

Legal Provisions and Sentencing

The applicable law in this case is Article 294, paragraph 2, of the Revised Penal Code, which addresses penalties for robbery resulting in violence or intimidation, particularly when accompanied by rape. The Court noted that the crime fell under provisions demanding reclusion perpetua due to being committed by multiple armed persons. The Court lamented that, in light of current constitutional pr

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