GR L 42665; (June, 1988) (Digest)
G.R. No. L-42665 June 30, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SILVESTRE SUNPONGCO, HERMINIGILDO SUNPONGCO and ARSENIO CALAYAG, defendants-appellants.
FACTS
The defendants-appellants were convicted by the Court of First Instance of Bulacan for the complex crime of forcible abduction with rape against complainant Juanita Angeles. The prosecution’s evidence established that on October 23, 1964, the appellants, together with Benjamin Gabriel, used a car to intercept a passenger jeep carrying Angeles and her companion, Benita Fabian, in Guiguinto, Bulacan. The appellants boarded the jeep, forced it to an isolated area, and then, employing violence and the threat of a gun, forcibly abducted Angeles. She was taken to the Hill Top Hotel in Tagaytay City, where accused Silvestre Sunpongco raped her twice. A medical examination confirmed recent sexual intercourse and physical injuries. During trial, the court discharged Benjamin Gabriel to become a state witness over defense objections.
ISSUE
The primary issue is whether the evidence sufficiently proves the guilt of the appellants beyond reasonable doubt for the complex crime of forcible abduction with rape, particularly focusing on the existence of conspiracy among them.
RULING
The Supreme Court affirmed the conviction but modified the penalty terminology. The Court upheld the finding of conspiracy, which was integral to holding all appellants liable as co-principals. Conspiracy was inferred from their collective and coordinated actions before, during, and after the abduction. The appellants acted in concert: they jointly intercepted the jeep, collectively participated in forcing Angeles into their car (with Silvestre pulling her, Gabriel pushing her, Arsenio manning the getaway vehicle, and Herminigildo restraining Fabian), and together transported her to Tagaytay. This unity of purpose and synchronized execution demonstrated a community of criminal design.
The Court also found no error in the trial court’s discharge of Benjamin Gabriel as a state witness. The legal requirement is that the discharged accused does not appear to be the most guilty, not that he must be the least guilty. Based on the evidence, the trial court’s determination on this point was sound. The testimonies of the victim and her companion, corroborated by the medical findings and the detailed account of the coordinated actions, constituted proof beyond reasonable doubt. However, the Court corrected the penalty imposed from “life imprisonment” to the proper legal term of reclusion perpetua and increased the civil indemnity to P30,000.00.