GR 219830; (August, 2016) (Digest)
G.R. No. 219830 , August 03, 2016
People of the Philippines, Plaintiff-Appellee, vs. Roberto O. Batuhan and Ashley Planas Lacturan, Accused-Appellants.
FACTS
On August 3, 2008, around 1:30 A.M., private complainants AAA and Melito Gabutero Bacumo were waiting for a jeepney at a waiting shed in Cebu City. They were each held at knifepoint by two individuals, later identified as Roberto O. Batuhan and Ashley Planas Lacturan. Lacturan robbed Bacumo of his wristwatch and other belongings. Meanwhile, Batuhan dragged AAA about 100 meters away, covered her mouth, poked her with a knife, kissed her neck, touched her breasts, and, under threat of being stabbed, inserted his finger into her vagina. He then took her bag containing cash and jewelry. AAA sought help from barangay tanods who apprehended Batuhan and Lacturan. Batuhan was charged with robbery with rape, and Lacturan was charged with robbery. Both pleaded not guilty, and the cases were jointly tried. The Regional Trial Court (RTC) convicted Batuhan of robbery with rape and sentenced him to reclusion perpetua, and convicted Lacturan of robbery. The Court of Appeals (CA) affirmed the convictions but modified Lacturan’s penalty and held that civil liabilities should be individual, not joint.
ISSUE
1. Whether the trial court erred in finding that the prosecution proved the guilt of the accused-appellants beyond reasonable doubt.
2. Whether the trial court erred in holding accused-appellants jointly liable to pay damages.
RULING
The Supreme Court denied the appeal. It affirmed the convictions, upholding the findings of the lower courts that the prosecution witnesses’ testimonies were credible, straightforward, and consistent, and that the area was sufficiently lit for identification. The defenses of denial and alibi were rejected. The Court agreed with the CA that civil liability should be imposed individually, as the accused were not charged as co-conspirators. However, the Court modified the penalty for Lacturan under the Indeterminate Sentence Law, setting the maximum term at eight (8) years of prision mayor. Batuhan was ordered to pay AAA ₱2,130 as civil indemnity and ₱50,000 as moral damages. Lacturan was ordered to pay Bacumo ₱2,500 as civil indemnity and ₱20,000 as moral damages.