Case Summary (G.R. No. 92626-29)
Charges and Jurisdiction
Ramos faced separate charges in the Regional Trial Court, 11th Judicial Region, Branch 29, Bislig, Surigao del Sur, comprising three counts of rape and one count of attempted rape, based on the Revised Penal Code, Article 335. The specific criminal cases are:
- Criminal Case No. 300: Rape of Felicisima Pabor
- Criminal Case No. 301: Rape of Dominga Rosal
- Criminal Case No. 302: Rape of Cristina Pejo
- Criminal Case No. 303: Attempted Rape of Leizel Recta
Facts of the Case
The four complainants decided to sleep in the UCCP parsonage on July 31, 1986, when Ramos entered through a window and threatened them with a firearm. He first raped Pabor and then moved on to Rosal and Pejo, all while intimidating them. Leizel Recta managed to escape and subsequently informed her mother about the incident. Eyewitness testimonies from the victims were consistent and detailed, corroborated by medical examinations revealing signs of sexual assault.
Trial Proceedings
After a trial where Ramos pleaded not guilty, the Regional Trial Court found him guilty beyond reasonable doubt of raping Pabor, Rosal, and Pejo. He was sentenced to three separate life imprisonments and ordered to pay moral damages to the victims. The court acquitted him of the attempted rape charge against Recta due to insufficient evidence.
Appeal and Assignments of Error
In his appeal, Ramos raised allegations of errors made by the trial court, primarily contesting the sufficiency of the prosecution's evidence and the credibility of the witnesses. He argued that:
- The trial court misapplied the standard for proof beyond a reasonable doubt.
- The identification of him by the victims was flawed.
- The complainants were not convincingly intimidated, and there were inconsistencies in the timing of the events.
- The testimonies given by the complainants were unnecessary, and possible motives for false accusations were unduly disregarded.
Court’s Evaluation of Evidence
The Supreme Court upheld the trial court's findings, emphasizing that the testimonies of the complainants were credible and consistent with the medical evidence. The court rejected the defense of alibi due to the proximity of Ramos’s house to the crime scene and the inherent weaknesses often associated with such defenses. The Court artic
...continue readingCase Syllabus (G.R. No. 92626-29)
Case Overview
- The case involves four separate criminal charges against Former Corporal Mario Ramos of the 28th Infantry Brigade of the Philippine Army.
- The crimes include three counts of rape and one count of attempted rape committed against four schoolgirls aged between thirteen and nineteen years.
- The incidents occurred in the UCCP Parsonage, Poblacion, Tagbina, Surigao del Sur, on the night of July 31 to August 1, 1986.
Incident Details
Criminal Case No. 300:
- Date: July 31, 1986
- Time: Approximately 11:30 PM
- Victim: Felicisima Pabor
- Description: Ramos entered the parsonage, brandished a firearm, threatened the victim, and raped her against her will.
Criminal Case No. 301:
- Date: August 1, 1986
- Time: Between 12:30 AM to 1:30 AM
- Victim: Dominga Rosal
- Description: Similar circumstances to the first case; Ramos used threats and intimidation to rape Rosal.
Criminal Case No. 302:
- Date: August 1, 1986
- Time: Between 2:00 AM to 2:30 AM
- Victim: Cristina Pejo
- Description: Ramos again brandished a firearm and raped Pejo.
Criminal Case No. 303:
- Date: August 1, 1986
- Time: Approximately 3:00 AM
- Victim: Leizel Recta
- Description: Recta managed to escape before the rape could be completed.
Trial Proceedings
- The Regional Trial Court of Bislig, Surigao del Sur found Ramos guilty in a Joint Decision promulga