Case Summary (G.R. No. 129533)
Charges and Arraignment
The offense was formally initiated by the Assistant Provincial Prosecutor of Albay, based on Maribel's written complaint, which alleges that the accused, motivated by lewd design and taking advantage of his moral ascendancy as her father, committed sexual intercourse with Maribel without her consent. Upon arraignment, the accused pleaded not guilty to the charges.
Prosecution's Evidence
During the trial, Maribel Pedres testified about the alleged incident, stating that she was abruptly awakened by her father restraining her and subsequently raping her. Testimony from her older sister, Maricel, supported the claims, detailing Maribel's disclosure to her after the event, which led to Maribel being examined by a physician, Dr. Maria Nimfa Joji QuiAones. The medical findings indicated various healed lacerations and physical evidence consistent with sexual assault.
Defense Testimony
The defense presented an alibi to contest the accusations, asserting that the accused was elsewhere during the incident—specifically, in Bagsa, Oas, Albay—from January 4 to January 7, 1996. Testimonies from the accused’s sister, Angelita Bron, and brother-in-law, Norberto Bulacan, supported this alibi. They testified that the accused was working on a ricefield and had no opportunity to commit the crime in Macalidong.
Trial Court's Findings
After evaluating the testimonies and evidence, the trial court determined that the prosecution established the essential elements of rape beyond reasonable doubt. It imposed the death penalty and mandated the accused to provide monetary indemnity to the victim.
Appeal and Argument Points
The accused-appellant raised two principal grounds for appeal: first, the reliance on the complainant's testimony, which he characterized as incredible, and second, the claim that the prosecution failed to meet the burden of proof for conviction beyond reasonable doubt. He argued that details of the incident were inconsistent and implausible, particularly regarding the circumstances surrounding Maribel's physical state and lack of immediate reporting.
Court’s Analysis of Testimony
The appellate court meticulously dissected Maribel's testimony, finding it coherent and consistent despite confrontations about minor discrepancies. The court addressed the behavior of Maribel during the incident, asserting that fear and trauma could inhibit natural reactions during such distressing experiences. The testimony concerning her father's threats further substantiated her failure to report immediately to her mother.
Rejection of Alibi and Final Consideration
The appellate court systematically rejected the alibi defense, stating that it is inherently weak compared to positive identification by the victim. It ruled that the trial court's assessment of the credibility of Maribel's testimony, given her age and the relationship with the accused, wa
...continue readingCase Syllabus (G.R. No. 129533)
Case Overview
- Parties Involved: The case involves the People of the Philippines as the plaintiff-appellee and Antonio Pedres y Buag as the accused-appellant.
- Case Citation: 366 Phil. 257 EN BANC [G.R. No. 129533, April 30, 1999].
- Nature of the Case: The accused is charged with the crime of rape under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659.
Background of the Case
- Date of Alleged Crime: January 5, 1996, at midnight.
- Location: Barangay Macalidong, Municipality of Ligao, Province of Albay, Philippines.
- Victim: Maribel Pedres, the daughter of the accused.
- Accusation Details: The Assistant Provincial Prosecutor of Albay filed information alleging that the accused used force and intimidation to have sexual intercourse with Maribel against her will.
Trial Proceedings
- Plea: The accused pleaded not guilty upon arraignment.
- Testimonies:
- Prosecution: Maribel testified about the incident, stating she was awakened by her father tying her hands and feet, then he removed her shorts and raped her.
- Witnesses: Maribel’s sister, Maricel, and a physician, Dr. Maria Nimfa Joji QuiAones, provided supporting testimony regarding the physical examination and findings on Maribel.
- Defense: The accused presented his alibi, supported by his sister Angelita Bron and brother-in-law Norberto Bulacan, claiming he was in another location at the time of the incident.
Key Points of the Prosecution's Case
- Victim's Testimony: Maribel described being attacked in her sleep, the actions of her father, and the physical and emotional aftermath of the incident.
- Medical Examination Findings: The physician not