Case Summary (G.R. No. 169077)
Petitioner, Respondent, and Court Hierarchy
The petitioner is the People of the Philippines, represented as the plaintiff-appellee, while the respondent is the accused-appellant, Nicanor Salome. The Regional Trial Court of Virac, Catanduanes initially decided on the matter, followed by a review from the Court of Appeals, and ultimately a decision from the Supreme Court.
Facts of the Case
On February 18, 1998, a complaint was initiated by Sally Idanan against Nicanor Salome alleging that he raped her within the timeframe of July 1 to July 31, 1997. Sally testified that she was threatened at knifepoint while sleeping with her younger brother when the accused forced himself upon her, resulting in her becoming pregnant. Medical examination confirmed her pregnancy, which led her to report the crime to authorities on November 17, 1997.
Initial Trial Decision
The Regional Trial Court found Nicanor Salome guilty of rape, sentencing him to death by lethal injection. The case was elevated for review due to the imposition of the death penalty.
Court of Appeals' Ruling
On June 15, 2005, the Court of Appeals affirmed the Regional Trial Court's decision, modifying the damages awarded: increasing civil indemnity to P75,000, moral damages to P75,000, and exemplary damages to P25,000. The court maintained that the trial court's assessment and characterization of the events were credible.
Standard of Credibility in Testimony
The trial court assessed Sally's testimony as credible and lacking ulterior motives, noting her immaturity and the nature of the threats she faced. The Court emphasized that a victim's sole testimony can suffice to establish guilt, particularly when corroborated by subsequent actions such as reporting the assault after confirming her pregnancy.
Defense Arguments
Salome's defense was based on alibi and assertions that Sally's behavior was inconsistent with a victim of rape. He claimed to have been fishing during the crime and suggested that Sally failed to resist or report promptly. The Court countered these claims, highlighting the intimidation involved and the psychological impact of the threat, which could understandably suppress responses typical of a person in distress.
Evaluation of Alibi Defense
Salome's alibi was deemed weak as his testimony lacked sufficient proof to establish impossibility of being at the crime scene. The trial court noted that being absent for only a few days did not negate his presence during the larger timeframe in which the crime was committed.
Use of Weapon and Aggravating Circumstance
The trial also considered the use of a deadly weapon as an aggravating circumstance, justifying the imposition of the death penalty per Article 335 of the Revised Penal Code, which prescribes severe penalties for rape under violent and aggravated circumstances.
Changes Following Legal Reform
Subsequent to the decision, Republic Act No. 9346 was enacted, prohibiting the imposit
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Case Overview
- This case involves a review of the Decision rendered by the Court of Appeals on June 15, 2005, affirming the decision of the Regional Trial Court of Virac, Catanduanes.
- The accused, Nicanor Salome, was found guilty beyond reasonable doubt of the crime of rape against a minor, Sally Idanan, and sentenced to death.
- The case was elevated to the Supreme Court for automatic review due to the imposition of the death penalty.
Background of the Case
- An information was filed against Nicanor Salome (also known as Canor Sabeniano) on February 18, 1998, following a complaint by Sally Idanan.
- Sally, then thirteen years old, testified that on a morning in July 1997, Salome entered her house while she was asleep and threatened her with a knife.
- The rapist undressed Sally and forced her to have carnal knowledge while threatening her life and that of her family if she reported the incident.
- Sally became pregnant as a result of the assault and reported the incident to the police on November 17, 1997.
Proceedings in the Trial Court
- The prosecution's case relied primarily on Sally's testimony and the medico-legal report that indicated she had sustained injuries consistent with sexual assault.
- The defense presented alibi witnesses who claimed Salome was fishing on the days in question, but the trial court found this defense lacking in credibility.
- On April 3, 2001, the trial court convicted Salome, imposing the death penalty, monthly support for the child, and civil indemnity to Sally.
Court of Appeals Decision
- The Court of Appeals