Title
People vs. Sanchez
Case
G.R. No. 121039-45
Decision Date
Jan 25, 1999
Brutal 1993 rape-slay of Eileen Sarmenta and Allan Gomez by Mayor Sanchez and accomplices; upheld convictions for rape with homicide, rejecting alibi defenses.

Case Summary (G.R. No. 187013)

Key Dates

Principal criminal acts: Night of June 28, 1993 and early morning of June 29, 1993 (abduction, rape, and killings).
Arrests, detentions, investigative events, and pretrial proceedings occurred in June–August 1993.
(Decision date and appellate procedural dates are not shown here per instruction.)

Applicable Law and Constitutional Basis

Applicable legal framework: Philippine criminal law as applied by the trial court and the Supreme Court, with reliance on controlling jurisprudence cited in the decision. Because the appellate decision postdates 1990, the 1987 Philippine Constitution is the constitutional backdrop for issues implicating constitutional rights (notably the right to a fair trial and issues concerning publicity and due process).

Facts as Found by the Trial Court (Concise Chronology)

On June 28, 1993, the accused, acting in concert, allegedly abducted two students, Eileen Sarmenta and Allan Gomez, from UP Los Baños. The abductors transported the victims to Erais Farm (owned by the Mayor), where Eileen was taken to the Mayor’s room and sexually assaulted; Allan was beaten and later killed. The group then moved Eileen to a sugarcane field where multiple accused allegedly raped her in succession and thereafter she was killed. The bodies were later discovered and identified; the prosecution presented a chain of events traced largely through the testimony of Centeno and Malabanan and corroborative forensic and physical evidence.

Prosecution Evidence and Witness Testimony

The prosecution’s narrative rested principally on the live testimony of Aurelio Centeno and Vicencio Malabanan, who admitted participation in the abduction but denied personal involvement in the rapes and killings. Their courtroom testimony described the sequence of abduction, transport to Erais Farm, involvement of the Mayor and other accused, the beating and killing of Allan, the gang-rape and murder of Eileen, and subsequent events (e.g., handling of remains and clothing). The trial judge found both witnesses credible based on their direct testimony and performance under extensive cross-examination.

Defense Version (Alibi and Alternate Suspects)

Each appellant primarily asserted alibi or denial, claiming presence elsewhere during the critical period. A recurring defense theory advanced throughout trial testimony implicated a different individual (referred to as “Kit Alqueza”) and his associates as possible perpetrators. Multiple accused claimed coercion, torture, or inducement by investigators to make statements implicating the appellants. Several appellants described sustained physical and psychological pressure during police and military interrogations; others asserted they surrendered or were accompanied by officials at various times in ways meant to show nonparticipation.

Trial Court’s Credibility Findings and Their Weight

Judge Demetriou conducted an extensive credibility assessment after a 16-month trial and concluded that Centeno and Malabanan were credible and their testimonies coherent and detailed. The trial court’s impressions—formed from observing witness demeanor, consistency under prolonged cross-examination, and the ability to recount numerous details—were explicitly adopted by the appellate court. The Supreme Court emphasized the established principle that trial courts are best positioned to evaluate witness credibility and that their determinations are entitled to great respect and, absent compelling reasons, should not be disturbed on appeal.

Treatment of Contradictions and Sworn Statement Variations

Appellants highlighted inconsistencies in Centeno’s multiple sworn statements and certain minor discrepancies in details. The trial court and the Supreme Court reviewed those contradictions but accepted Centeno’s in-court explanations (fear, coercion by some investigators, later retraction when under witness protection) as reasonable. The courts applied the well-settled principle that discrepancies in minor or collateral details, or between early sworn statements and later courtroom testimony, do not necessarily destroy credibility—particularly where the principal narrative remains consistent and where a plausible explanation for variance is offered.

Corroborating Physical and Forensic Evidence

The appellate decision relied not only on testimonial identification but also on physical and forensic corroboration:

  • A missing belt loop recovered from Erais Farm was forensically matched in color, size, and fiber composition to a belt loop detached from the white shorts worn by Eileen on the night of the crime.
  • An M16 empty shell found at the site where Allan’s body was located was ballistically linked to M16 cartridges from an M16 rifle bearing a serial number surrendered by Luis Corcolon, per ballistic examination.
  • Metallic fragments recovered from Eileen’s body were microscopically consistent with fragments from a bullet fired from an M16 rifle.

These evidentiary links strengthened the prosecution’s account and supported the trial court’s factual findings.

Medical and Autopsy Findings

The medico-legal report by Dr. Vladimir V. Villaseñor showed multiple contusions, fresh shallow lacerations on the hymen, congested cervix, gaping labia majora, and oozing whitish fluid that tested positive for spermatozoa—evidence consistent with multiple seminal ejaculations and nonconsensual sexual assault. The prosecution’s forensic expert interpreted these findings as inconsistent with consensual intercourse. The defense medical expert opined differently on aspects of the findings, but the trial court—and ultimately the appellate court—found the prosecution’s medical evidence persuasive and the defense expert’s objectivity potentially compromised by relationship to the Mayor.

Assessment of Alibi and Failure of Corroboration

The appellants’ alibi defenses were largely unsupported by independent corroboration. The Court noted that alibi claims crafted or primarily supported by the accused themselves or immediate relatives are inherently weaker. Where credible eyewitness identification and corroborative physical and forensic evidence exist, uncorroborated alibis were held insufficient to undermine the prosecution’s case.

Claims of Coercion and Police/Military Misconduct

Several accused complained of coercion, torture, or inducements during investigation and detention, alleging that some statements were extracted under duress and that investigators sought to frame certain individuals. The trial and appellate courts considered these claims but evaluated them against the totality of the record, including the in-court credibility of witnesses whose testimonies were consistent, the presence of corroborative physical evidence, and the trial judge’s findings after assessing demeanor and performance under cross-examination. The appellate court gave weight to the trial court’s determinations that the principal witnesses’ courtroom testimony was reliable despite allegations of earlier duress or inducement.

Publicity and the Right to a Fair Trial

Appellants argued pervasive media coverage prejudiced their right to an impartial trial. The Court re

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.

About Privacy Terms