People v. Matias y Anglo

 

People v. Matias y Anglo

G.R. No. 247002

April 12, 2023

FACTS:

                Accused-appellant, together with Jun Villegas and Udebs Gonzales, was inculpated for 3 counts of Rape. At around 11om, AAA went home with another friend, CCC. While they were traversing at 12 midnight, accused-appellant and his co-accused suddenly appeared behind them. Villegas pointed a gun at AAA’s nape and dragged them towards an alley near a half-basketball court. He then pushed her against a wall, removed her lower garments and forcibly inserted his penis into her vagina. AAA began to cry and swore not to tell anyone about what transpired. She was also told not to make any noise lest she be killed. In the meantime, accused-appellant and Gonzales held and frisked CCC. Subsequently, AAA was pulled into another alley where accused-appellant forced her to lie down on a flight of stairs and raped her. All the while, Villegas held her legs and Gonzales guarded the alley. AAA's tribulation came to a close when Gonzales raped her while accused-appellant pinned down her legs. At this point, Villegas had already fled the scene. AAA was still in tears and powerless to shout because Gonzales took a page from accused-appellant's book and gripped her mouth. When Gonzales was finished with the deed, he left together with accused-appellant. Thereafter, AAA went to her cousin's house along and was able to knock on the door before passing out. After regaining her consciousness, she relayed to DDD, the wife of her cousin, her ordeal of being raped thrice. At around 4:00 a.m., AAA's mother EEE was apprised of what happened to her daughter. Afterwards, EEE accompanied AAA and DDD to the barangay hall along to report the incident. Eventually, AAA gave her statement against accused-appellant and his co-accused at the Quezon City Police Station 6 (PS6).

ISSUE:

                Whether or not accused-appellant is guilty of rape.

HELD:

                No. The accused before the Court is presumed innocent. This presumption continues although the accused had been convicted in the trial court, as long as such conviction is still pending appeal. It is axiomatic that an appeal in criminal cases opens the entire case for review, and it is the duty of the reviewing tribunal to correct, cite, and appreciate errors in the appealed judgment whether they are assigned or unassigned. The appeal confers the appellate court full jurisdiction over the case and renders such court competent to examine records, revise the judgment appealed from, increase the penalty, and cite the proper provision of the penal law. In this case, accused-appellant contends that the presence of at least 5 of the danger signals that the Court enunciated in People v. Pineda tainted his identification by AAA as one of the culprits. A successful prosecution of a criminal action largely depends on proof of 2 things: one, the identification of the author of the crime; and two, his actual commission of the same. The constitutional presumption of innocence that an accused enjoys is not demolished by an identification that is full of uncertainties.

                In synthesis, the identification of accused-appellant failed to meet the touchstone of reliability. While his defenses of denial and alibi are inherently weak, they are only so in the face of an effective identification, which does not obtain in this case. It is hornbook doctrine that a slight doubt created in the identity of the perpetrators of the crime should be resolved in favor of the accused. Perforce, while a felony ineludibly transpired in this case, the Court is constrained to acquit accused-appellant on the ground of reasonable doubt.