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PEOPLE v. BONFILO MARTINEZ Y DE LA ROSA

FACTS:

On December 28, 1991, accused-appellant Bonfilo Martinez and two unidentified persons allegedly entered the house of Ernesto Buenvinida in Caloocan City armed with guns. They tied the hands of the occupants and proceeded to rob them of various items, including cash and valuables. During the robbery, Glorivic Bandayanon was sexually assaulted against her will and without her consent. The two unidentified accomplices remain at large.

Appellant was arrested on March 3, 1994, for soliciting funds for a fictitious volleyball competition and was confined at the Bagong Silang Sub-station detention cell before being transferred to the Caloocan City Jail. During his arraignment on March 21, 1994, appellant pleaded not guilty to the charges. Glorivic Bandayanon and Michael Buenvinida, prosecution eyewitnesses, testified about the circumstances of the crime. The accused entered the house while the occupants were watching TV, one pretending to be a policeman and the others covering their faces. They tied and detained the occupants in the master's bedroom, while appellant and one accomplice searched the house for valuables. Appellant untied Michael and ordered him to unplug the appliances. The accused found cash, perfume bottles, and other valuables and placed them in a bag. The group leader took Glorivic to the children's bedroom, raped her, and was later joined by another accomplice who also raped her. Glorivic identified appellant as one of the assailants during the trial.

Another account of the incident states that Glorivic and Michael were at the Buenvinida residence when three men entered the house on December 28, 1991. The first man pointed a gun at Glorivic, while the second man tied her hands and raped her. The third man also raped her and covered her face with a bed sheet. Michael witnessed the men entering and leaving the room and heard Glorivic crying for help. After the assault, the third man told Glorivic to dress up, and she noticed blood flowing down her thighs. The men threatened to explode a hand grenade and left. Glorivic and Michael then reported the incident to the police.

On March 7, 1994, Glorivic and Michael separately identified appellant as one of the perpetrators. Glorivic recognized him because of a mole on his right cheek, and Michael identified him as the person who ordered him to unplug the appliances during the robbery. The appellant denied any involvement in the crime, claiming to have met Glorivic and Michael for the first time on March 7, 1994. He presented an alibi, stating that he was at his house in Parañaque on the day of the incident, but later admitted visiting his brother in Bagong Silang in 1991. The trial court found appellant guilty of robbery with rape and sentenced him to reclusion perpetua.

ISSUES:

  1. Whether or not the identification of the accused by the witnesses was credible.

  2. Whether or not the appellant was liable for the value of the stolen personal properties and damages to the victim, Glorivic Bandayanon.

RULING:

  1. The Supreme Court held that the identification of the accused by the witnesses was credible. The court affirmed that the witnesses had sufficient opportunity to observe the appellant during the commission of the crime, and their testimonies were consistent and corroborative. The court also emphasized the natural reaction of victims to remember the appearance of their assailants and there was no indication that the witnesses had any improper motive.

  2. The Supreme Court ruled that the appellant was liable for the value of the stolen personal properties and damages to Glorivic Bandayanon. The court found that even though the value of the stolen items was derived from an affidavit considered hearsay, the testimony of the investigating officer and the opportunity for cross-examination negated the hearsay rule. The trial court rightly took judicial notice of the value of the stolen goods. The award of P30,000.00 for moral damages to Glorivic Bandayanon was increased to P50,000.00 due to the multiple rape under humiliating circumstances.

PRINCIPLES:

  1. Credibility of Witnesses: The trial court's findings on credibility are generally accorded great respect and finality unless there are substantial reasons to overturn them.

  2. Natural Reaction to Criminal Violence: Victims of criminal violence are inclined to remember the appearance of their assailants and the manner of the crime, which helps in the accurate identification of the perpetrators.

  3. Judicial Notice: Courts can take judicial notice of facts within public knowledge or capable of unquestionable demonstration without need for formal evidence.

  4. Hearsay Rule Exception: Testimony that might otherwise be considered hearsay can be admissible if there were adequate opportunities for cross-examination and the testimony was necessary to ascertain facts during a criminal investigation.

  5. Civil Liability in Criminal Cases: The value of stolen goods and damages awarded for emotional distress or moral damages are pertinent when determining the civil liabilities of the accused in criminal cases.