Case Digest (G.R. No. 145726)
Facts:
People of the Philippines v. Ferdinand Antonio, G.R. No. 145726, March 26, 2003, Supreme Court En Banc, Per Curiam, writing for the Court. The accused-appellant is Ferdinand Antonio; the victim/complainant is identified in the record as AAA.On October 6, 1998 the Provincial Prosecutor of Isabela filed three Informations charging appellant with three separate counts of rape allegedly committed against his daughter AAA in November 1996 (Br. 24‑0681), February 1997 (Br. 24‑0682) and January 1998 (Br. 24‑0683). At arraignment on February 10, 1999 appellant pleaded not guilty to all counts and the three cases were tried jointly before the Regional Trial Court (RTC), Branch 24, Echague, Isabela.
At trial AAA testified in detail to repeated incidents of forcible intercourse by her father, describing threats with a knife and acts of penetration; her testimony was corroborated by a medical examination performed on February 26, 1998 by Dr. Theresa Dalmacio, who found a ruptured hymen with laceration and recorded AAA’s statement that her first sexual contact occurred in November 1996 and the last in January 1998. Appellant testified and denied the charges, arguing that he was often away working, that AAA would have been pregnant if intercourse had occurred, and that the family conspired to fabricate the allegations; he admitted the filial relationship and that he was married to AAA’s mother.
The RTC, after trial, acquitted appellant in Criminal Cases Nos. Br. 24‑0681 and Br. 24‑0682 but convicted him in Criminal Case No. Br. 24‑0683 of rape, sentencing him to death and ordering payment of P50,000 as moral damages. Because the penalty imposed was death, the criminal record in Br. 24‑0683 was forwarded to the Supreme Court for automatic review under the rule...(Pro-only)
Issues:
- Was the conviction in Criminal Case No. Br. 24‑0683 defective because the prosecution allegedly failed to formally offer its documentary exhibits?
- Were the prosecution’s photocopied documents inadmissible under the best-evidence rule?
- Did the prosecution prove rape beyond reasonable doubt and specifically prove the qualifying circumstances (minority and filial relationship) necessary to sustain the death penalty under Republic Act No. 8353? ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)