PEOPLE v. ELEUTERIO BRAGAT

FACTS:

The case involves the appeal of Eleuterio Bragat, who was convicted by the Regional Trial Court (RTC) for the special complex crime of robbery with rape. Bragat, along with his co-accused Jundie Balvez, was charged with committing robbery with rape against the spouses AAA and BBB. According to the prosecution, Bragat and his companions forcibly entered the house of the spouses, armed with firearms and a bladed weapon. They restrained the spouses and demanded money. Bragat proceeded to rape AAA at gunpoint. After taking the couple's money and jewelry, Bragat and his companions fled the scene. The spouses reported the incident, and AAA underwent a medical examination that did not identify any sperm. Bragat, in his defense, denied knowing his co-accused or the spouses and claimed that he was at his employer's house during the incident. Nevertheless, the RTC found Bragat guilty of robbery with rape.

ISSUES:

  1. Whether or not appellant is guilty beyond reasonable doubt of the crime of robbery with rape.

  2. Whether or not the prosecution sufficiently proved the elements of robbery and rape.

RULING:

  1. Yes, appellant is guilty beyond reasonable doubt of the crime of robbery with rape. The RTC found the testimony of the victim, AAA, to be credible and consistent with the evidence presented. AAA positively identified appellant as the one who raped her and participated in the robbery. Moreover, the RTC considered other circumstantial evidence, such as the entry of appellant and his companions into the victims' house, the use of force and intimidation, and the taking of the victims' money and earrings. These elements, when taken together, prove beyond reasonable doubt the guilt of appellant for the crime charged.

  2. Yes, the prosecution sufficiently proved the elements of robbery and rape. The testimony of AAA, coupled with the physical examination conducted by the doctor, supports the prosecution's case. The prosecution presented evidence that appellant and his companions forcibly entered the victims' house, used violence and intimidation, and took their money and jewelry. Moreover, AAA's testimony regarding the rape was corroborated by the medical findings of the doctor. The prosecution has thus proven all the elements of robbery and rape beyond reasonable doubt.

PRINCIPLES:

  • Credibility of witnesses - The court may give weight and credence to the testimony of a witness if it is credible and consistent with the evidence presented.

  • Circumstantial evidence - Circumstantial evidence, when taken together, may establish the guilt of the accused beyond reasonable doubt.