PEOPLE v. JIMMY SABREDO Y GARBO

FACTS:

The case involves the complex crime of abduction with rape committed by the accused-appellant, Jimmy Sabredo, against the complainant Judeliza Sabredo. The appellant is the uncle of the complainant and had been staying with her family in Cebu. On June 27, 1994, the appellant forcibly abducted the complainant at knife point and brought her to various locations in Masbate while continuously threatening her with the knife. The appellant sexually assaulted the complainant on July 4, 1994, and severely injured her when she tried to escape. They eventually stayed at the house of the appellant's sister, where the complainant was able to report her ordeal to the police. The appellant was charged with forcible abduction with rape, and during the trial, he claimed that the sexual relations between him and the complainant were consensual. The trial court convicted the appellant and sentenced him to death. The case is now on automatic review, with the appellant challenging the credibility of the complainant's testimony and the correctness of his conviction.

ISSUES:

  1. Whether the trial court erred in evaluating the honesty of the private complainant's testimony.

  2. Whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt of the crime charged.

RULING:

  1. The Supreme Court held that there was no error in the evaluation of the private complainant's testimony. The inconsistencies pointed out by the accused-appellant were merely minor and did not affect the credibility of Judeliza's testimony as a whole. Moreover, her testimony was corroborated by the medical examination and the testimonies of other witnesses. Thus, the trial court's reliance on her testimony was reasonable and logical.

  2. The Supreme Court affirmed the trial court's finding of guilt and its imposition of the penalty of death on the accused-appellant. The evidence presented during trial conclusively established the appellant's guilt beyond reasonable doubt. The testimonies of the victim, the medical examination, and the corroborating testimonies of witnesses all pointed to the appellant as the perpetrator of the crime. The Supreme Court also noted that the trial court properly appreciated the qualifying circumstances of force and intimidation, which elevated the crime to forcible abduction with rape. Therefore, the judgment of conviction and the penalty imposed were affirmed.

PRINCIPLES:

  • Inconsistencies in the testimony of a witness that are immaterial or insignificant, and do not affect the essential points of the case, do not necessarily discredit the testimony as a whole.

  • The evaluation of the credibility of witnesses is primarily the function of the trial court, which has the advantage of observing their demeanor, conduct, and attitude during trial. Its findings in this regard are entitled to great respect and will generally not be disturbed on appeal, unless it is shown that the trial court overlooked material and substantial matters that would have affected the outcome of the case.