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PEOPLE v. ADEL TUANGCO

FACTS:

From the excerpts, it is established that the victim, Aurea Eugenio, was a bookkeeper residing in Apalit, Pampanga, and working in a credit cooperative in Manila. On January 3, 1995, she brought a camera and cash to her office with the intention of taking pictures of her officemates and spending on their town fiesta.

Between 7:00 and 7:30 in the evening, the bus carrying the victim stopped at Sitio Dalan Baka, where she disembarked. To her misfortune, the road leading to her house was dimly lit and secluded. At the waiting shed near the highway, the three accused, Sonny Tuangco, Adel Tuangco, and Nelson Pineda Jr., were present along with Silvestre Sanggalan, the prosecution eyewitness.

Adel Tuangco approached the victim, forcibly undressed her, and proceeded to rape her. Subsequently, Sonny Tuangco and Nelson Pineda Jr. took turns raping the victim while the others held her hands. Following the assault, the accused took the victim's belongings: Adel took her bag, Nelson took her camera and cash, and Sonny took her ring, earrings, and watch. The victim sustained severe injuries, including lacerations on her hymen and breasts, neck stab wounds, and massive bleeding, leading to her death.

Both Sonny Tuangco and Adel Tuangco denied their involvement in the crimes. Sonny claimed to be alone in his house in Bulacan, while Adel presented an alibi. The case is supported primarily by the testimony of Silvestre Sanggalan, a deaf-mute witness who identified Adel Tuangco as one of the individuals he was with on the night of the incident.

It is also revealed that prior to the incident, the accused and Silvestre Sanggalan were drinking at a beer house in Calumpit, Bulacan, with four other individuals. Later, the accused and Sanggalan left their companions and went to a rice field near the highway. They stayed inside a waiting shed across the road where the victim had disembarked. Sonny Tuangco and Nelson Pineda consumed Pidol cough syrup while inside the shed. Eventually, they left the shed and pursued the victim, while telling Sanggalan to depart. However, Sanggalan hid and witnessed the entire ordeal. Nelson Pineda Jr. pushed the victim, and Adel Tuangco seized her shoulder bag. Sonny Tuangco and Nelson Pineda Jr. pinned the victim against a tree and stabbed her multiple times in the neck. Adel Tuangco joined in the stabbing until the victim collapsed. While she was on the ground, Nelson Pineda Jr. inserted the bottle of Pidol cough syrup into her private parts with Sonny Tuangco's assistance. Despite the victim being alive and fighting back, Adel Tuangco continued to assault her while also removing her clothing.

ISSUES:

  1. Whether the trial court erred in giving full faith and credence to the testimony of the eyewitness, Silvestre Sanggalan, who is a deaf-mute and unschooled.

  2. Whether the trial court erred in finding both accused guilty beyond reasonable doubt of two counts of the special complex crime of rape with homicide and theft.

RULING:

  1. Credibility of Eyewitness Testimony: The Supreme Court affirmed the trial court's credibility assessment, holding that a deaf-mute is not incompetent as a witness and that the interpreter's qualifications were adequate. The minor inconsistencies in the eyewitness's testimony did not detract from its credible and positive identification of the accused-appellants.

  2. Guilt Beyond Reasonable Doubt: The Supreme Court upheld the trial court's conviction of the accused-appellants for rape with homicide and theft, affirming the imposition of two death penalties on each accused for the complex crime of rape with homicide, and the indeterminate penalty for theft.

PRINCIPLES:

  • Competence of Deaf-mute Witnesses: Deaf-mutes are competent witnesses if they can understand and appreciate the sanctity of an oath, comprehend facts they are going to testify on, and communicate their ideas through a qualified interpreter.

  • Minor Inconsistencies in Testimony: Minor inconsistencies in a witness's testimony indicate authenticity rather than fabrication and do not undermine the overall credibility of the witness.

  • Positive Identification over Alibi: Positive identification by a credible witness prevails over the defense of alibi.

  • Conspiracy: Conspiracy is established when there is unity of purpose in the commission of the crime, as evidenced by collective acts leading to its perpetration.

  • Civil Indemnity for Homicide: The prevailing jurisprudence mandates a civil indemnity of P100,000.00 for the victim's death in cases of rape with homicide.

  • Exemplary Damages: Such damages are awarded when aggravating circumstances, like cruelty, are present.