Case Digest (G.R. No. 179280)
Facts:
People of the Philippines v. Pedro Calangi, G.R. No. 179280, August 27, 2009, Supreme Court Second Division, Carpio Morales, J., writing for the Court. The appellant is Pedro Calangi alias Haplas; the appellee is the People of the Philippines.Appellant was charged before the Regional Trial Court (RTC), Branch 61, Gumaca, Quezon, in four Informations: Criminal Case Nos. 6886-G and 6887-G (two counts alleging rape of AAA, his daughter‑in‑law) and Criminal Case Nos. 6888-G and 6889-G (two counts alleging rape of BBB, his granddaughter, a minor). The Informations described force, threats and use of a firearm; the 6888–6889 informations invoked Article 266‑A/266‑B of R.A. No. 8353 and the 6886–6887 informations invoked Article 335 as amended by R.A. No. 7659.
At trial the prosecution presented AAA and BBB as complainants and other witnesses; medical examination showed BBB was pregnant. Appellant pleaded alibi and denial; two defense witnesses claimed to have been with him during the alleged incidents. By Decision dated June 23, 2005, the RTC convicted appellant on all four counts, imposing reclusion perpetua for the counts involving AAA and death (with accessory penalties) for the counts involving BBB, and awarded civil and moral damages.
On appeal the Court of Appeals, in a Decision dated March 21, 2007, modified the RTC judgment: it acquitted appellant in Criminal Case Nos. 6887‑G and 6889‑G for insufficiency of evidence, but affirmed convictions in Criminal Case Nos. 6886‑G and 6888‑G (recluding the penalties and damages). The present matter was then brought to the Supreme Court (G.R. No. 179280). During the pendency of the appeal, the Bureau of Corrections informed the Court that appellant died on April 1, 2009 at the National Bilibid Prisons Hospital.
Because of appellant’s death the Court recognized that dismissal of the cases was in order and that such dismissal has th...(Pro-only)
Issues:
- Upon the appellant’s death, should the criminal cases be dismissed and what is the legal effect of such dismissal on his criminal conviction and civil liabilities?
- Were the remaining convictions (Criminal Case Nos. 6886‑G and 6888‑G) supported by evidence beyond reasonable doubt given the witnesses’ inconsistencies, vagueness as to ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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