Facts:
On April 14, 2013, AAA, a 12-year-old minor, and her friend JJJ were accosted by Ismael and eventually introduced to Carlo, Obat, and Kalbo. After refusing initially, AAA was coerced into drinking alcohol. Later, at a vacant lot, AAA, now dizzy and drowsy, was raped successively by the accused and his companions. Her pleas and resistance were futile, as they forcibly held her down. The victim sought help the next day, leading to a medical examination revealing blunt penetrating trauma to her genitalia. Carlo Diega y Zapico was arrested and charged with the crime of rape under Article 266-A, Paragraph 1(a) of the Revised Penal Code, along with three unidentified individuals referred to as “John Does.” After a trial, the Regional Trial Court (RTC) found Carlo guilty and sentenced him to reclusion perpetua. Carlo appealed, but the Court of Appeals (CA) affirmed the conviction, adjusting the awarded damages.
Issues:
1. Whether the testimony of AAA is credible.
2. Whether the existence of conspiracy among the perpetrators was established.
3. Whether Carlo’s defense of denial and alibi can be sustained.
Court’s Decision:
The Supreme Court dismissed the appeal, affirming the findings of the CA and RTC. The Court recognized the consistent and clear testimony of AAA regarding the sequence and manner of the rape incidents that identified Carlo and his companions as her attackers. The Court acknowledged the established principle in jurisprudence that the testimony of rape victims should be given credence. It found the argument of Carlo urging inconsistency in AAA’s testimony to be without merit.
Furthermore, the Supreme Court found that there was a conspiracy to commit the crime of rape among Carlo and his three companions who were at large, as evidenced by their simultaneous and coordinated actions, and held Carlo liable for all four counts of rape. Multiple precedents were cited where the Court had held an individual responsible for the collective acts of a criminal conspiracy. The defenses of denial and alibi presented by Carlo were dismissed due to their inherent weakness and lack of substantial evidence to uphold them.
Doctrine:
1. The credibility of a rape victim’s testimony is upheld where it is consistent on material points and the witnesses appear trustworthy.
2. The existence of conspiracy can be deduced from the coordinated acts of the accused aimed at attaining a common goal.
3. In conspiracy, each conspirator is equally responsible for acts committed by others in the pursuit of their common design.
4. A negative defense like alibi must be supported by clear and convincing proof to be preferred over the positive identification by a credible witness.
Class Notes:
– The gravamen of rape under Article 266-A of the Revised Penal Code is sexual congress with a woman against her will, with or without her consent.
– Conspiracy requires positive identification of each participant’s actions in furtherance of a common design.
– A defendant’s bare denial and alibi, absent compelling evidence, are generally insufficient to overcome the prosecution’s case.
– Rape victims are not expected to resist until death, and resistance can be manifested in any outward physical act demonstrating non-consent.
Historical Background:
Rape laws in the Philippines have evolved mainly to protect and provide justice to victims, emphasizing the victims’ experience and perspective. As such, the credibility of a victim’s account is held in high esteem, particularly where the testimony is clear, consistent, and persuasive. This case reflects the strict application of such legal principles that aim to preserve and protect the rights and dignity of rape victims. It also illustrates the legal principle that each member of a conspiracy is liable for acts committed by any other member in furtherance of the common unlawful aim.
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