Case Summary (G.R. No. 247806)
Charges and Legal Proceedings
Generoso Sujetado was charged with rape under the allegation that he used force, violence, and intimidation to have carnal knowledge of Livy Montelibano, who was below twelve years of age at the time of the incident. Following an arraignment where the accused pleaded not guilty, the lower court convicted him, sentencing him to reclusion perpetua, monetary indemnification to the victim, and additional civil penalties.
Appellate Claims
In his appeal to the higher court, Sujetado raised several claims regarding errors made by the lower court, including improper reliance on the victim's testimony, the failure to establish that the alleged crime occurred as claimed, and the validity of a purported conspiracy against him orchestrated by the victim's family. He contended that evidence presented by the defense was insufficiently addressed or deemed credible by the lower court.
Testimony of the Complainant
Livy Montelibano testified about being enticed to the accused's house where the alleged rape occurred. She described a scenario in which Sujetado forcibly removed her clothing and engaged in sexual intercourse, after which he allegedly attempted to compensate her with a small sum of money. Livy's testimony was corroborated by her cousin, Jeffrey Samartin, who reported that Livy confided in him shortly after the event, leading to a medical examination.
Medical Examination Results
The medical examination conducted post-incident recorded findings that included signs of previous sexual activity rather than fresh injuries indicative of recent rape. Specifically, the results indicated old healed hymenal lacerations, leading to questions about Livy's claims of recent trauma and supporting the defense's argument about the improbability of the alleged offense.
Defense Testimony and Alibi
Generoso Sujetado presented an alibi, supported by testimonies from his family and acquaintances who claimed that he was preoccupied with activities related to his role as a hacienda overseer during the time of the alleged offense. The defense argued that the accusations against him were motivated by familial ambition to remove him from his position, a claim bolstered by testimony from the hacienda owner regarding the dismissal policy of employees under criminal charges.
Judicial Analysis of Credibility
The appellate court examined both the prosecution's and defense's arguments, noting significant discrepancies and weaknesses in the testimony of the prosecution witnesses. The Court highlighted the lack of supportive evidence for Livy's account and the implausibility of the chain of events presented by the prosecution. The testimony of Livy showed inconsistencies, and the circumstances of the alleged crime suggested a high degree of implausibility concerning the accused's opportu
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Case Background
- The accused, Generoso Sujetado y Esmellarin, faced charges of rape concerning an alleged incident occurring on March 21, 1988, in Bacolod City, Philippines.
- The charge specifically claimed that the accused unlawfully had carnal knowledge of the complainant, Livy Montelibano, who was a minor below twelve years of age, through force, violence, and intimidation.
Arraignment and Lower Court Decision
- During arraignment, the accused pleaded not guilty to the charges.
- The lower court eventually found the accused guilty, sentencing him to reclusion perpetua, ordering him to indemnify the victim, and imposing civil interdiction for life and perpetual absolute disqualification.
Appeal and Assigned Errors
- The accused appealed the conviction, raising several alleged errors by the lower court, including:
- The sole reliance on the victim's testimony, which was doubted even by her mother.
- Evidence presented by defense witnesses contradicting the possibility of the crime being committed as alleged.
- Claims of a frame-up to displace the accused from his position as overseer of the hacienda.
- Errors in the interpretation of medical examination findings and the significance of witness testimonies.