Case Summary (G.R. No. 121039-45)
Petitioner and Respondent
Petitioner: The People of the Philippines. Respondents/Accused-Appellants: Sanchez et al.
Key Dates
RTC conviction: prior to 1999. SC decision affirming conviction: January 25, 1999. Resolution on motions for reconsideration: October 18, 2001.
Applicable Law
Criminal liability for rape with homicide under the Revised Penal Code. Rights to due process and fair trial under the 1987 Constitution. Civil indemnity, actual and moral damages under Articles 2199 and 2216, Civil Code, and relevant jurisprudence.
Procedural History
- Pasig RTC found appellants guilty beyond reasonable doubt of seven counts of rape with homicide and awarded various civil damages.
- SC, in January 1999, affirmed the conviction and added P350,000 indemnity per accused.
- Appellants moved for reconsideration on issues of publicity bias, witness credibility, alibi, and damages. SC resolution on October 18, 2001.
Issues Raised in Motions for Reconsideration
– Alleged trial and conviction by prejudicial publicity.
– Credibility and impeachment of prosecution witnesses Aurelio Centeno and Vicencio Malabanan.
– Reliance on the alibi of Sanchez’s 13-year-old daughter.
– Excessiveness and factual basis of the awarded civil damages.
Denial of Prejudicial Publicity Claim
SC reaffirmed that extensive media coverage alone does not establish actual bias. Citing People v. Teehankee, Jr. and Martelino v. Alejandro, the Court held appellants failed to prove that the judge was unduly influenced by publicity; mere possibility of prejudice is insufficient.
Credibility of Witnesses
Trial court’s positive assessment of Centeno and Malabanan—spontaneous, consistent testimony under cross-examination—was accorded finality. Minor inconsistencies were deemed collateral and did not impair credibility, in line with People v. Mendoza and People v. Agomo-o.
Alibi Defense
The testimony of Sanchez’s daughter, uncorroborated and offered by a close relative, was held insufficient. Alibi unsupported by independent evidence is the weakest defense (People v. Waggay) and cannot prevail over positive identification of Sanchez at the crime scene.
Review of Civil Damages
Original RTC awards:
• Sarmenta heirs: P3,432,650 actual damages + P2,000,000 moral + P164,250 litigation.
• Gomez heirs: P3,484,000 actual damages + P2,000,000 moral + P191,000 litigation.
SC had added P350,000 indemnity per accused, resulting in possible double recovery.
Adjustment of Civil Indemnity and Funeral Expenses
– Civil indemnity: Deduct P50,000 per family to eliminate duplication.
– Funeral expenses: Uphold P106,650 for Sarmenta (receipted); delete P74,000 for Gomez (no receipts) but grant P10,000 nominal damages.
Computation of Lost Earning Capacity
Using the formula Net Earning Capacity = Life Expectancy × (Gross Annual Income – Living Expenses), with assumed 1993 figures of P96,000 gross and P36,000 expenses:
• Sarmenta (age 21): Life expectancy factor 2/3(80–21)=39.353 → P2,361,180
• Gomez (age 19): Life expectancy factor 2/3(80–19)=40.687 → P2,441,220
Reduction of Moral Damages
Moral damages reduced from P2,000,000 to P1,000,000 per family to align with indemnity’s true compensatory purpose and proportionality under Article 2216, Civil Code, and Dela Serna v. CA.
Attorney’s Fees and Litigation Expenses
Original awards of P164,250 (Sarmenta) and P191,000 (Gomez) confirmed as reasonable given
Case Syllabus (G.R. No. 121039-45)
Procedural Background
- Branch 70 of the Pasig City Regional Trial Court convicted the accused-appellants of seven counts of rape with homicide and imposed reclusion perpetua for each count.
- The trial court ordered each appellant to pay ₱700,000 as additional indemnity to the heirs of the two victims, plus actual, moral, and exemplary damages.
- On January 25, 1999, the Supreme Court (Special First Division) affirmed the conviction and damage awards in toto.
- Accused-appellants filed motions for reconsideration contesting the conviction and damages; the Office of the Solicitor General filed its comment on December 6, 1999.
- Following Justice Martinez’s retirement, the motions were raffled on September 18, 2001 to Justice Melo, who prepared this resolution.
Facts of the Case
- Victims: Eileen Sarmenta and Allan Gomez, both senior students at UPLB’s College of Agriculture.
- Appellants, led by Mayor Antonio L. Sanchez, were found to have committed rape with homicide against the two victims at Erais Farm.
- Prosecution’s principal witnesses: Aurelio Centeno and Vicencio Malabanan, whose testimonies identified the appellants at the crime scene.
- Defense alibi: Mayor Sanchez presented his 13-year-old daughter’s testimony claiming he was elsewhere; other appellants offered uncorroborated denials of participation.
Motions for Reconsideration
- Mayor Sanchez argued:
- He suffered trial and conviction by extensive media publicity.
- Principal witnesses lacked credibility and were impeached by inconsistent prior statements.
- His daughter’s alibi testimony should prevail over prosecution evidence.
- The awards of “gargantuan” damages lacked factual and legal basis.
- Co-appellants Zoilo Ama, Baldwin Brion, and Pepito Kawit contended:
- Prosecution witnesses were sufficiently impeached.
- Independent witnesses disproved the prosecution’s version of events.
Issues Reiterated on Reconsideration
- Whether pervasive publicity denied appellants an impartial trial.
- Whether Centeno’s and Malabanan’s credibility was fatally undermined.
- Whether alibi testimony of a close relative warranted acquittal.
- Whether the amounts of actual, moral, and additional indemnity damages were excessive or unsupported.
Appellate Court’s Prior Ruling (January 25, 1999)
- Held that:
- Conviction by publicity requires p