Title
People vs. Peralta
Case
G.R. No. 83812
Decision Date
Dec 7, 1995
On July 12, 1983, Merlyn Robinos was robbed and raped by Enrico Peralta and Cosme Tamor in Pasig. Despite the absence of external injuries or sperm, the Supreme Court upheld their conviction, citing credible testimony, conspiracy, and sufficient evidence of rape and robbery. Moral damages were increased.

Case Summary (G.R. No. 83812)

Summary of the Incident

On the night of July 12, 1983, Merlyn Robinos was waiting for a ride after placing an order for earrings at Eastland. She hailed a tricycle, initially believing it was driven by her acquaintance Antonio Flores. However, the driver was actually Enrico Peralta, and his companion was Cosme Tamor. Tamor brandished an icepick, announced a robbery, and forced Robinos into the tricycle, where he tied her mouth with a handkerchief, robbing her of personal items valued at approximately P1,430. The attack escalated to sexual violence when Peralta took her to a vacant lot and raped her despite her struggle and pleas for mercy.

Procedural History

The case against the appellants was formally initiated with the filing of an Information on July 18, 1983, accusing them of robbery and rape. Upon their arraignment, both appellants entered a plea of "not guilty." During the trial, the prosecution presented detailed evidence corroborated by Robinos’s testimony, medical examination findings, and witness accounts.

Evidence Presented

The prosecution's case included the account of Robinos, who described her horrific experience in detail. Additionally, a Medical Examination Report indicated signs consistent with forced sexual intercourse, despite the lack of visible physical injuries. Defense witnesses presented a counter-narrative, claiming that Robinos had invited them into a sexual encounter, which Robinos vehemently denied.

Trial Court's Findings and Decision

The trial court, after assessing the evidence and testimonies, rendered a verdict on April 5, 1988, convicting both appellants of robbery with rape. The court concluded that the crime was committed in conspiracy, utilizing a deadly weapon, and thus imposed the penalty of reclusion perpetua. The appellants were also ordered to pay damages to Robinos.

Appellants' Arguments on Appeal

The appellants challenged the trial court's decision, emphasizing inconsistencies between Robinos's testimonies and her earlier affidavit. They argued that minor discrepancies were significant enough to invalidate her account and credibility. However, the court noted that such differences are inherent in human recollection and do not undermine the reliability of the witness's statements.

Ruling on the Appeal

Upon review, the court upheld the trial's decision, finding no substantial basis for overturning the co

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