Case Digest (G.R. No. 132779-82)
Facts:
The People of the Philippines v. Donato Bernaldez y Lamagan, G.R. Nos. 132779-82, January 19, 2000, the Supreme Court En Banc, Mendoza, J., writing for the Court.The prosecution (the People) charged Donato Bernaldez y Lamagan (accused-appellant) with four counts of rape for acts allegedly committed against his daughter, Mary Jane Bernaldez. Mary Jane was born April 19, 1979, and testified that her father raped her four times between December 23, 1996 and February 24, 1997 at their home in Taguig. She described threats by her father that he would kill her and her siblings if she reported the incidents. Her younger sister Marivic and aunt Jonalyn Ramos observed circumstances that led to filing a complaint on February 24, 1997. Mary Jane underwent medico‑legal examination (Feb. 26, 1997) by Dr. Llamas; the report found findings “compatible with recent sexual intercourse” and positive spermatozoa, but no external signs of violence.
At trial, Marivic and Jonalyn corroborated having seen the accused embracing Mary Jane on the papag on Feb. 24; SPO2 Cahanding testified concerning the complaint and the accused’s invitation for questioning. Accused-appellant testified as sole defense witness, denying the rapes, offering alibis for some dates, and asserting an alleged motive for the accusations — that Jonalyn and Mary Jane conspired to seize his assets. The Regional Trial Court (RTC), Branch 163, Pasig City, found the accused guilty beyond reasonable doubt of four counts of rape and, in its November 25, 1997 decision, imposed the death penalty for each count and ordered payment of P500,000.00 as moral damages to Mary Jane.
The case came to the Supreme Court on automatic review of death sentences. The accused assigned errors that the RTC erred in finding guilt proved beyond reasonable doubt and in giving ...(Subscriber-Only)
Issues:
- Was accused-appellant’s guilt proven beyond reasonable doubt?
- May the death penalty be imposed where the informations alleged only the complainant’s minority but failed to allege the filial relationship that qualifies the rape for the death penalty?
- Was the trial court’s award of P500,000.00 as moral damages proper, and what monetary awards should properly a...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)