Case Summary (G.R. No. 121039-45)
Parties
Petitioner: The People of the Philippines
Respondents (Accused-Appellants): Mayor Antonio L. Sanchez; George Medialdea; Zoilo Ama; Baldwin Brion; Luis Corcolon; Rogelio Corcolon; Pepito Kawit.
Key Dates
June 28–29, 1993: Abduction, gang rape, and killing of Eileen Sarmenta and Allan Gomez
March 11, 1995: RTC Decision convicting all accused of seven counts of rape with homicide
January 25, 1999: Decision of the Court of Appeals affirming RTC verdict
Applicable Law
1987 Philippine Constitution (due process, right to fair trial)
Revised Penal Code, Article 335 (rape) as qualified by homicide
Rules on Evidence and Criminal Procedure
Facts of the Crime
On June 28, 1993, Centeno drove an ambulance with Medialdea, Malabanan, Ama, and the Corcolon brothers under the pretext of pursuing a criminal suspect. At UP Los Baños, the group abducted Eileen and Allan from a van. They transported them to the Mayor’s Erais Farm, where Eileen was gagged and taken to the Mayor’s room while Allan was beaten. The Mayor and six accomplices thereafter loaded both into the van, shot Allan en route to Calauan, proceeded to a sugarcane field, repeatedly raped Eileen, and finally shot her to death.
Trial Court Findings
RTC found the testimony of Centeno and Malabanan credible and sufficient to establish conspiracy, abduction, rape, and homicide beyond reasonable doubt. Each accused was sentenced to reclusion perpetua on seven counts and ordered to pay civil indemnities and damages totaling millions of pesos to the victims’ families.
Issues on Appeal
Appellants challenged:
- Credibility of State witnesses Centeno and Malabanan
- The defense of alibi and alternative suspect theory involving “Kit Alqueza”
- Alleged inconsistencies between sworn statements and live testimony
- Claims of torture during custodial interrogation
- Prejudicial media coverage affecting fair trial
Credibility of Witnesses
The trial judge, having observed eighteen days of testimony and seven attorneys’ cross-examinations, ruled Centeno and Malabanan were frank, consistent, and detailed. This Court accorded deference to those findings, noting the trial judge’s superior position to assess demeanor and candor. Minor contradictions were classified as collateral and did not affect the core narrative.
Defense of Alibi and Alternative Theory
Each appellant claimed absence from crime scenes and attributed culpability to “Kit Alqueza.” Except for the Mayor’s daughter and Medialdea’s neighbor, no material corroboration of alibi was produced. The Court held that positive identification by credible witnesses overcame unsupported alibi defenses, and held the alternate-suspect theory unsubstantiated.
Inconsistencies in Sworn Statements
Centeno executed four separate affidavits between August 13 and 30, 1993. Discrepancies regarding location details and mention of “Kit Alqueza” were explained by the witness as fear-induced misstatements under CIS custody and subsequent corrections once protected. Jurisprudence permits crediting live testimony over prior inconsistent affidavits when explanations are plausible.
Corroborating Expert Evidence
Major Lulita Chambers matched a belt loop from Erais Farm to the victim’s shorts. Ballistics expert Vicente de Vera linked an M16 shell found at Allan’s body site to Luis Corcolon’s rifle. Medico-legal officer Dr. Villaseñor documented hymenal laceratio
...continue readingCase Syllabus (G.R. No. 121039-45)
Facts of the Crime
- On the night of June 28, 1993, a group led by city officials and police officers abducted students Eileen Sarmenta and Allan Gomez at the U.P. Los Baños campus, using an ambulance as transport.
- The abductors delivered the victims to Erais Farm in Barangay Curba, owned by Mayor Sanchez; Eileen was gagged, bound and brought into the mayor’s resthouse while Allan was beaten and expelled outside.
- After the mayor’s sexual assault on Eileen, the group drove off in a Tamaraw van and an ambulance toward Sitio Paputok in Barangay Mabacan; Allan was executed en route, and Eileen was gang-raped and shot dead in the sugarcane field.
- State witnesses Aurelio Centeno and Vicencio Malabanan—co-conspirators turned informants—testified to every stage: recruitment of participants, the abduction ruse, the mayor’s involvement, the beatings, the rape sequence, and the final killings.
- Bodies and physical evidence (Eileen’s torn shorts, Allan’s body, M-16 shell casings) were discovered, processed by police and forensic experts, and linked by ballistic and fiber analyses to the accused.
Procedural History
- Trial before Pasig RTC, Branch 70 (Judge Harriet O. Demetriou) lasted 16 months, produced a 132-page Decision (March 11, 1995) convicting all appellants of seven counts of rape with homicide.
- Each appellant was sentenced to seven reclusion perpetua terms and ordered to pay civil indemnities and damages totaling millions of pesos to the Sarmenta and Gomez families.
- Appellants appealed to the Supreme Court, raising errors on witness credibility, alibi defenses, and claimed prejudicial publicity.
Issues Presented
- Whether the prosecution’s star witnesses—Centeno and Malabanan—were credible despite discrepancies in their sworn statements.
- Whether the appellants’ alibi defenses and denials created reasonable doubt as to their participation.
- Whether minor inconsistencies in open-court testimony fatally undermined the case.
- Whether pervasive media coverage and pretrial publicity prevented a fair and impartial adjudication.
Findings of the Trial Court on Credibility
- Judge Demetriou observed Centeno’s “frank, spontaneous and straightforward manner,” noting that a three-month cross-examination failed to expose serious flaws.
- Malabanan likewise displayed truthfulness with no signs of evasiveness, earning “full faith and credit” in his testimony