Case Summary (G.R. No. L-61870)
Trial and Initial Rulings
Following a trial at the Court of First Instance of Isabela, Constantino Peralta was found guilty as charged, while Antolin Pua was acquitted due to insufficient evidence. Peralta was sentenced to seventeen years, four months, and one day of reclusion temporal, as well as ordered to pay damages. The trial court's decision was appealed by Peralta to the Court of Appeals.
Court of Appeals Decision
The Court of Appeals upheld the conviction but found the sentence imposed by the trial court to be erroneous. Notably, the court cited that the applicable law at the time of the crime classified rape committed under such circumstances as punishable by reclusion perpetua to death, as per Republic Acts No. 2632 and No. 4111, thus rendering the trial court's sentence incorrect.
Evidence Presented
The essential facts presented in the case indicate that Thelma Agustin, at the age of seventeen, was waylaid and raped by Peralta and Pua. Thelma recognized the accused during the assault and sustained physical injuries as confirmed by medical examination. Upon regaining consciousness following the assault, she was found in a disheveled state, which corroborated her testimony regarding the events of the evening.
Testimonies
The testimonies from both Thelma Agustin and corroborating witnesses indicated that she had previously met Peralta just days before the incident, which strengthened the identification of the accused. Upon regaining consciousness, Thelma immediately communicated the details of the assault to her aunt and later to her parents, leading to the immediate reporting of the crime to local authorities.
Defense's Position
Peralta and Pua denied the allegations, claiming an alibi that they were together at a restaurant during the time of the crime. However, their defense was undermined by testimonies from witnesses that were inconsistent, particularly with regard to the timeline established by the prosecution.
Rulings on Credibility
The court placed significant weight on the credibility of Thelma's testimony. It concluded that the details regarding her identification of Constantino Peralta were consistent and reliable, undermining the defense's assertions of mistaken identity. The court emphasized the necessity
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Case Overview
- The case involves Constantino Peralta y Dasuga and Antolin Pua y Mateo, who were charged with the crime of rape.
- The incident occurred on April 25, 1975, in Alicia, Isabela, where the accused allegedly conspired to sexually assault Thelma E. Agustin against her will.
- The trial court found Peralta guilty, sentencing him to 17 years, 4 months, and 1 day of reclusion temporal, while Pua was acquitted due to insufficient evidence.
- Peralta appealed the conviction, which was affirmed by the Court of Appeals but with a correction to the imposed penalty.
Facts of the Case
- Thelma Agustin, 17 years old, and her cousin went to watch a movie but separated afterward.
- After waiting for her cousin, Thelma attempted to go home but was waylaid by three men, including Peralta and Pua.
- Peralta and Pua physically assaulted her, with Peralta allegedly boxing her in the abdomen, rendering her unconscious.
- Upon regaining consciousness, Thelma discovered she was naked and in pain, indicating she had been raped.
- Thelma reported the assault to her aunt and subsequently to the police, identifying Peralta as one of her attackers.
- A medical examination confirmed signs of rape, including lacerations and the presence of sperm.
Legal Proceedings
- The c