G.R. Nos. L-38551-53 February 27, 1987
People of the Philippines vs. Claudio Veloso, et al.

FACTS

On the evening of June 22, 1972, three young girls—Rosita Rubio (15), Constancia de los Reyes (14), and Rosanna Rodriguez (12)—were at a public park in Lucena City. They were initially approached by a group of seven men, including appellant Claudio Veloso. The group later returned, surrounded the girls, and forcibly dragged them to the Capitol Building. There, the men successively raped the three victims. Veloso personally raped Rosita Rubio, threatening her with a bolo. After the assaults, the victims reported the incident to the police. Medical examination confirmed recent hymenal lacerations. Veloso was arrested and signed an extrajudicial confession. He was charged, along with others, with three counts of rape.
At trial, Veloso claimed he and Rosita were sweethearts and that their sexual intercourse was consensual. He also sought to discredit his extrajudicial confession, alleging coercion. The trial court convicted him of three counts of rape, imposing the death penalty. Veloso appealed, arguing the trial court erred in crediting the victims’ testimonies, in admitting his confession, and in holding him liable for rapes he did not personally commit.

ISSUE

The primary issue is whether the trial court correctly convicted Claudio Veloso of three counts of rape based on conspiracy.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court found the testimonies of the three victims credible and consistent in their material points. Minor inconsistencies were deemed natural and did not undermine their core narrative. The claim of a sweetheart relationship with Rosita was rejected as a self-serving, unbelievable attempt to disguise rape as consensual sex, especially given the violent context of the group assault.
Regarding the extrajudicial confession, the Court ruled it was admissible. The confession was obtained before January 17, 1973, the date established in Magtoto vs. Manguera from which the right to counsel during custodial investigations became mandatory. Veloso failed to substantiate his claim of coercion.
Most critically, the Court upheld Veloso’s liability for all three rapes under the principle of conspiracy. Conspiracy exists when two or more persons come to an agreement to commit a felony and decide to commit it. It can be inferred from the collective conduct of the accused. The evidence clearly showed conspiracy: the group acted in concert from initially approaching the girls, to forcibly taking them, to assisting each other during the sequential rapes. As a co-conspirator, Veloso is liable for the acts of his companions in furtherance of the common criminal design. Consequently, he is guilty of three counts of rape. The death penalties were reduced to reclusion perpetua (life imprisonment) in accordance with the 1987 Constitution .