Facts:
On the early morning of September 29, 1996, around 2:00 a.m., in Villaverde, Nueva Vizcaya, Philippines, Melencio Imbat and his daughter, Gloria Imbat, were asleep in their home. Baliwang Bumidang, half-naked and armed with a spear, arrived and threatened to kill them if they did not let him in. Fearful for their lives, Melencio let Bumidang into their home.
Once inside, Bumidang ordered Melencio to lie prone and pointed his spear threateningly at him to keep him compliant. Bumidang approached Gloria’s room, which was in the same space, but separated by an aparador (cabinet). Despite Gloria’s cries for help, Melencio remained immobilized by fear.
Bumidang used a flashlight to illuminate the situation, removed Gloria’s pajama and panty, removed his shortpants, and raped Gloria at spear-point. After satisfying his desires, Bumidang made verbal threats against Gloria and Melencio if they reported the incident. Gloria subsequently reported the incident to the authorities, and Bumidang was apprehended. Medical examination confirmed a hymenal laceration consistent with penetration.
The case was initially filed with the Municipal Circuit Trial Court of Villaverde-Quezon, and upon finding a prima facie case, it was elevated to the Regional Trial Court (RTC) of Bayombong, Nueva Vizcaya. Bumidang pleaded not guilty on May 14, 1997, but escaped custody on June 2, 1997, leading to an in absentia trial. The RTC found Bumidang guilty on July 10, 1997, imposing the death penalty and ordering him to pay P30,000 to Gloria.
Issues:
1. Whether the evidence was sufficient to prove Bumidang’s guilt beyond reasonable doubt.
2. Whether the aggravating circumstances of dwelling, nighttime, and ignominy were correctly appreciated.
Court’s Decision:
1. Guilt Beyond Reasonable Doubt:
The Supreme Court affirmed the RTC’s decision, finding the testimony of Gloria and her father credible, clear, and consistent. Bwumidang’s flight from the custody hinted at guilt. Inconsistencies in the affidavits and trial testimonies were deemed minor, insufficient to undermine their credibility. The Court emphasized the established rule that witness credibility assessments by trial courts are given significant weight unless there are strong contrary reasons, which were absent in this case.
2. Aggravating Circumstances:
– Dwelling: The Court upheld the aggravating factor of dwelling since the crime was committed in Gloria’s house without any provocation from her, violating the home’s sanctity.
– Nighttime: The Supreme Court reversed the RTC’s finding, concluding that Bumidang did not specifically seek nighttime, nor facilitated his crime using darkness; hence, nighttime was not proven to facilitate the crime.
– Ignominy: The Court agreed with the RTC, stating Bumidang’s examination of Gloria’s genitalia with a flashlight, committing the act in her father’s presence, aggravated her humiliation and moral suffering, warranting the imposition of ignominy as an aggravating factor.
The original conviction with the death sentence was upheld, with civil indemnity adjusted to P75,000, moral damages of P50,000, and exemplary damages of P25,000.
Doctrine:
The case reaffirms the principles that:
– Testimonies of rape victims, if credible and consistent, are critical in rape convictions.
– Aggravating circumstances must be clearly demonstrated; mere occurrence during nighttime, without clear benefit of darkness, does not suffice to establish nighttime as an aggravating factor.
– Victim statements’ inconsistencies considered minor reflect natural discrepancies in human memory.
Class Notes:
– Aggravating Circumstances (§14, Revised Penal Code): Dwelling (§14[3]), Nighttime (§14[6]), and Ignominy (§14[17]) can elevate penalties if proven based on offender’s intent and effect on crime facilitation.
– §335, Revised Penal Code: Rape with deadly weapon punishable by reclusion perpetua to death.
– Credibility of Witness Testimonies: Judged with high deference to trial courts absent significant error or omission in evaluation.
Historical Background:
This case exemplifies the period’s frequently contentious imposition of death penalty in heinous crimes under the influence of Republic Act No. 7659, which reimposed the death penalty in the Philippines in 1993. It contextualizes the judicial emphasis on evaluating witness credibility in rape cases, acknowledging societal and systemic challenges in prosecuting such personal crimes without bias or error, especially when corroborated by forensic evidence and conduct indicating guilt, like flight from custody.
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