Case Summary (G.R. No. 96053)
Applicable Law
The case is governed by the Revised Penal Code, particularly Article 335, which outlines the crime of rape. The decision relies on the 1987 Philippine Constitution, given that the judgment is dated May 13, 1998.
Facts of the Case
The complaint was filed on January 21, 1992, based on Clara Angcon's sworn statement. She testified that on the evening of August 11, 1991, while alone at her home, Venerable arrived requesting water and subsequently assaulted her. She described a violent encounter where she was repeatedly raped over several hours. Following the incident, Angcon delayed seeking medical help due to the distance to the town center and fear of encountering her assailant. On August 26, 1991, Dr. Fe L. Besario examined Angcon, finding minor physical evidence but stating that this was expected given the time that had elapsed since the assault.
Trial Court Decision
The trial court found Venerable guilty of rape, concluding that the prosecution had established his guilt beyond reasonable doubt. As a result, he was sentenced to reclusion perpetua and ordered to pay Angcon moral damages amounting to P30,000.
Grounds for Appeal
Venerable appealed the conviction while raising several errors regarding the trial court's evaluation of evidence. He contended that the court placed undue weight on the testimony of Angcon, claiming it was unreliable. Moreover, he argued that his own evidence, which suggested an alibi, was disregarded inappropriately.
Defense and Testimony
Venerable's defense rested on denial and alibi, asserting he was home at the time of the incident. He presented his sister-in-law as a witness to corroborate his claims. However, his testimony contained contradictions regarding his whereabouts, which undermined the credibility of his alibi. Furthermore, his suggestion that he and Angcon had a romantic relationship was not supported by substantial evidence.
Analysis of Credibility
The decision emphasized the importance of witness credibility, noting that Angcon's testimony was straightforward and plausible in light of her circumstances. It was concluded that her account of the events was not only consistent but also bore the marks of someone recounting a traumatic experience. The court maintained that w
...continue readingCase Syllabus (G.R. No. 96053)
Case Overview
- The case revolves around the conviction of Inoferio Venerable, also known as Porferio Venerable, for the crime of rape, as adjudicated by the Regional Trial Court in Dumaguete City on March 31, 1993.
- The case was appealed to the Supreme Court, with the decision issued on May 13, 1998.
Parties Involved
- Plaintiff-Appellee: The People of the Philippines
- Accused-Appellant: Inoferio Venerable, alias Porferio Venerable
Background of the Case
- The charge was initiated by a sworn complaint from Clara Angcon, leading to the filing of the Information on January 21, 1992.
- The alleged crime took place on August 11, 1991, around 7:00 PM, in Barangay Dobdob, Valencia, Negros Oriental, within the jurisdiction of the court.
- The Information accused the appellant of using force and intimidation to have sexual intercourse with the complainant against her will, violating Article 335 of the Revised Penal Code.
Trial Proceedings
- The accused pleaded not guilty during arraignment and waived the pre-trial, prompting the trial to commence.
- Prosecution's Evidence:
- Clara Angcon testified about her experience during the incident, detailing her interactions with the accused before the assault and describing the multiple acts of sexual violence she endured that evening.
- Dr. Fe L. Besario, the Medico-legal Officer, corroborated Clara's testimony regarding her medical examination conducted on August 26, 1991, and detailed the physical findings.
- Defense's Evidence:
- Inoferio Venerable denied the accusations, offering an alibi and claiming he was at home on the day of the incident.
- His sister-in-law, Teresita Alab