Case Digest (G.R. No. 131652) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bayani M. Alonte and Buenaventura Concepcion v. Hon. Maximo A. Savellano, Jr., et al. (G.R. Nos. 131652 & 131728, decided March 9, 1998), Mayor Bayani M. Alonte of Biñan, Laguna, and his associate Buenaventura Concepcion were charged with rape under Article 335(2) of the Revised Penal Code, as amended by R.A. No. 7659, for an alleged assault on September 12, 1996, in Sto. Tomas, Biñan. On December 5, 1996, complainant Juvielyn Y. Punongbayan filed an information, alleging that Alonte had drugged and then raped her, and that Concepcion had brought her to Alonte’s rest house in exchange for ₱1,000.00. The case was originally docketed as Criminal Case No. 9619-B before RTC Branch 25 of Biñan, Laguna. The victim later executed an affidavit of desistance on June 25, 1997, stating her wish to withdraw the complaint and discontinue proceedings. Despite this, the Supreme Court granted the victim’s petition for change of venue on September 2, 1997, transferring the case to RTC Branch Case Digest (G.R. No. 131652) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Criminal Information and Initial Proceedings
- On December 5, 1996, an information for rape was filed in RTC Biñan, Laguna (Crim. Case No. 9619-B) against Mayor Bayani M. Alonte and Buenaventura ‘Wella’ Concepcion, based on a complaint by 17-year-old Juvie-Lyn Y. Punongbayan alleging that on or about September 12, 1996, Alonte raped her after rendering her dizzy with tainted water and that Concepcion acted as an accomplice.
- Punongbayan, through counsel Atty. Remedios C. Balbin, and Asst. Chief State Prosecutor Leonardo Guiyab, Jr., petitioned this Court for a change of venue to Metro Manila, citing threats, harassment, and bribery attempts against the complainant and her witnesses.
- Affidavits of Bribery and “Desistance”
- In February and March 1997, Atty. Balbin executed two affidavits recounting repeated offers of at least ₱10 million (later ₱20 million) from emissaries of Mayor Alonte to induce her and Punongbayan to desist, accompanied by veiled threats.
- On June 25, 1997, Punongbayan, assisted by her parents and counsel, executed an “Affidavit of Desistance,” stating she wished to withdraw her complaint for personal and educational reasons and would not revive the case.
- Supreme Court Change of Venue Resolution
- On September 2, 1997, this Court granted the change of venue petition, finding a probability of illicit influence and undue pressure on the complainant and ordering the transfer of Criminal Case No. 9619-B to any branch of the RTC Manila.
- The Court directed the trial judge in Manila to resolve the voluntariness and validity of Punongbayan’s desistance affidavit in light of the public prosecutor’s opposition.
- Proceedings in RTC Manila, Branch 53
- On September 17, 1997, the case was raffled to Branch 53, RTC Manila, before Judge Maximo A. Savellano, Jr. Arrest warrants were issued; Alonte surrendered, Concepcion posted bail; both pleaded not guilty on October 7, 1997.
- Pre-trial was waived. On November 7, 1997, the prosecution—represented by Asst. State Prosecutor Marilyn R.O. Campomanes—presented Punongbayan and her parents, who affirmed their desistance affidavit, and moved for dismissal due to lack of evidence. Judge Savellano declared the case submitted for decision.
- Bail Applications and Trial Court Decision
- Between November 10 and December 10, 1997, Alonte repeatedly moved for bail (₱150,000), joined by the prosecution, but the trial court took no action.
- On December 18, 1997, in absentia, Judge Savellano promulgated judgment convicting both accused of rape, sentencing them to reclusion perpetua, and cancelling Concepcion’s bail.
- Petitions for Certiorari and Other Reliefs
- Alonte filed a motion for reconsideration followed by a consolidated petition for certiorari, prohibition, habeas corpus, bail, recusation of Judge Savellano, and disciplinary action.
- Concepcion filed his own petition for certiorari and mandamus. Grounds included denial of due process, conviction without trial, violation of Rules of Criminal Procedure and Evidence, and improper conviction of an accomplice as principal.
Issues:
- Whether the affidavit of desistance executed by the private complainant after the institution of the criminal case warrants dismissal of the rape charge.
- Whether the trial court committed grave abuse of discretion and denied the accused their right to due process by convicting them without conducting a regular trial and by violating the order of trial and confrontation guarantees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)