Case Summary (G.R. No. 99868)
Charges and Context of the Case
The accused were charged with the crime of robbery with rape, as stipulated under Article 294, paragraph 2 of the Revised Penal Code. The information indicated that on December 14, 1986, the group carried out a robbery armed with firearms and forcibly took money and items belonging to the victims, while also committing the act of rape against Elisa Austria during this crime.
Procedural History and Initial Rulings
Upon arraignment, Ariel Limbauan pled guilty to the charges, while the other accused, including Tamang, entered a not guilty plea. Following the trial, the court convicted Limbauan and Tamang, sentencing them to reclusion perpetua and civil indemnity, while the other accused received varying prison terms. Tamang alone appealed the decision, contesting his conviction of the complex crime of robbery in band with rape.
Appellant's Claims and Argument
Leonor Tamang contended that his actions during the incident, particularly leading Elisa Austria downstairs, did not imply involvement in the conspiracy behind the rape. He argued that he intended for her to join others and did not directly hand her over to Limbauan for the purposes of rape. The central argument was that he did not conspire with Limbauan to commit the act of rape.
Evaluation of Evidence
The court evaluated eyewitness testimony, particularly from the victim Elisa Austria, who testified about the force used against her and identified Tamang's role in bringing her downstairs before handing her over to Limbauan, who subsequently raped her. This critical account defined Tamang's participation, contradicting his claim of innocence concerning the conspiracy.
Conspiracy and Legal Interpretation
A conspiracy can be established through the actions of the parties involved, evidencing a common understanding to commit a crime. In this case, the court found substantial evidence of an agreement between Tamang and Limbauan, induced by the testimonies that showed Tamang’s actions were not merely about leading Austria downstairs but were part of a collusive act to facilitate the crime.
Affirmation of the Trial Court's Judgment
The appellate court affirmed the trial court’s ruling, establishi
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Case Overview
- The case is an appeal from the decision of the Regional Trial Court, Second Judicial Region, Branch 16, Ilagan, Isabela, in Criminal Case No. 778.
- The case involves charges against Ariel Limbauan alias Acio, Alfredo Laman, Leonor Tamang, Eliseo Sanchez, Rolando Tandayu, Lucio Afunay, and Nestor Luga, for the crime of robbery with rape.
- The trial court sentenced Ariel Limbauan and Leonor Tamang to Reclusion Perpetua and required them to pay civil indemnity.
- Other accused (Luga, Tandayu, and Afunay) received lesser sentences under the Indeterminate Sentence Law.
Facts of the Case
- The incident occurred on December 14, 1986, in Delfin Albano, Isabela, where the accused, armed with firearms, robbed Marcela G. Bacani and Primitivo C. Rodriguez.
- The total value of the stolen items amounted to P12,350.00 belonging to Bacani and P12,000.00 belonging to Rodriguez.
- During the robbery, Ariel Limbauan, with the assistance of Leonor Tamang, forcibly brought Elisa Austria downstairs and subsequently raped her.
Charges and Proceedings
- The accused were charged with robbery with rape under Article 294, paragraph 2, of the Revised Penal Code.
- Upon arraignment, Ariel Limbauan pled