People v. Dazo
REITERATIONFacts
The Antecedents: Appellants Donato Dazo and Filomeno Tiangzon were prosecuted for rape in the Court of First Instance of Leyte. Procedural History: They were tried, found guilty, and each sentenced to fourteen years, eight months, and one day of reclusion temporal, with accessory penalties, credit for half of their preventive imprisonment, and to pay half of the costs. They were also ordered to indemnify the offended party and to support any offspring. The Petition: The appellants contended that the trial court erred in accepting the testimony of the complaining witness and disregarding the defense witnesses.
Issue(s)
Whether the testimony of the complaining witness, without other witnesses to the commission of the crime, is sufficient for conviction. Whether the aggravating circumstances of ignominy and nocturnity were present in the commission of the crime.
Ruling
The judgment appealed from is affirmed with costs against the appellants.
Ratio Decidendi
On the sufficiency of the complaining witness's testimony: The Court held that while it is true that there were no other witnesses to the commission of the crime besides the complaining witness, the circumstances of the case fully corroborated her testimony. The Court emphasized that where the testimony of the prosecutrix is not inherently improbable or contradictory, it is not essential to a conviction that there be corroboration. This principle was supported by cited cases from other jurisdictions and a previous Philippine case. On the presence of aggravating circumstances: The Court disagreed with the Attorney-General that the aggravating circumstances of ignominy and nocturnity were present. It was not apparent that the defendants took advantage of the night-time to commit the offense. Regarding ignominy, the Court found that the facts of the present case were not as aggravated as those in the cited case of United States vs. Iglesia and Valdez, where the crime was committed against a married woman after separating her from her husband. Therefore, these circumstances were not considered to aggravate the offense.
Main Doctrine
The testimony of the prosecutrix, if clear and free from serious contradiction and not inherently improbable, is sufficient for conviction even without corroboration.