Case Summary (G.R. No. L-8892)
Facts of the Case
On June 17, 1998, an information was filed, alleging that the three accused, through force and intimidation, raped the minor victim. During the incident, the victim testified that she was lured to the designated location, forcibly taken into a classroom, and compelled to drink alcohol before being raped multiple times by all four men involved. The victim later disclosed the abuse to her mother, leading to a police report and a medical examination confirming signs of sexual assault.
Defense of the Accused
During the trial, Villanueva denied the allegations, claiming that the sexual acts were consensual and that the victim did not resist. His co-accused Verceles corroborated this claim, stating that the victim voluntarily engaged in the illicit acts. However, both claimed they were outside the room during the acts of sexual intercourse.
Trial Court's Decision
The Regional Trial Court of San Carlos City convicted Villanueva of rape, sentencing him to reclusion perpetua and imposing a civil indemnity of PHP 50,000 to the victim. The co-accused received lesser sentences due to their status as youthful offenders, with their punishments suspended.
Issues on Appeal
Villanueva appealed the conviction, arguing that the prosecution failed to establish his positive identification as one of the perpetrators, and contended that there was no sufficient evidence of force or intimidation used against the victim. He claimed that the victim initially joined them willingly and subsequently engaged in the sexual acts consensually.
Prosecution's Response
The prosecution countered that the victim's testimony was clear and consistent, identifying Villanueva as one of her assailants. The Office of the Solicitor General emphasized that the circumstances surrounding the crime, including the victim’s age and drugging with alcohol, supported the presence of force and intimidation.
Court's Analysis and Findings
The appellate court analyzed the credibility of the victim's testimony, highlighting her unwavering account of the events and the psychological impact of the trauma she endured. It noted that her age rendered her a vulnerable victim, making her statements inherently reliable. The court determined that even if Villanueva did not wield a weapon, the overwhelming circumstances, including the victim's intoxicated state and the isolation of the crime scene, constituted sufficient intimidation.
Conclusion on Guilt
Ultimately, the appellate court affirmed the trial court's ruling, stating that the prosecution proved Villanueva's guilt beyond reasonable doubt.
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Case Overview
- This case involves an appeal by Benigno V. Villanueva against the decision rendered by the Regional Trial Court of San Carlos City, Pangasinan, which convicted him of rape and sentenced him to reclusion perpetua.
- The trial court also ordered Villanueva to pay the victim, Marianne Pinky Limson, fifty thousand pesos (P50,000) as indemnity.
- The incident in question occurred on May 15, 1998, involving the victim, who was only 12 years old at the time.
Background of the Case
- An information dated June 17, 1998, charged the accused with rape under Article 335 of the Revised Penal Code, as amended by R.A. 7659.
- The accused, including Villanueva, initially pleaded not guilty but two of them later changed their plea to guilty, leading to a trial focused solely on Villanueva.
Prosecution's Version of Events
- The victim was a Grade VI pupil who visited a former classmate in Barangay Bani, Bayambang, Pangasinan.
- After failing to locate her friend, she was approached by Dennis Verceles, who claimed that Villanueva wanted to speak with her.
- Upon meeting Villanueva, she realized he was a stranger and attempted to leave but was forcibly taken by Verceles and two other men to the Bani Elementary School.
- The victim was compelled by the accused to drink alcohol, making her tipsy and weak.
- She testified that all four men took turns raping her, after which they left her at the school plaza.
- Villanueva and Buada returned later, where she was raped again before being told to return the following day.
Testimonies and Evidence Presented
- The victim's mother, Iluminada Limson, corroborate