Case Digest (G.R. No. 206958) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Primo Campuhan y Bello, G.R. No. 129433, decided on March 30, 2000, the accused, Primo Campuhan y Bello, was charged with statutory rape for allegedly molesting four-year-old Crysthel Pamintuan on April 25, 1996, at the Pamintuan residence in Malabon. At around 4:00 p.m., Ma. Corazon P. Pamintuan, mother of the victim, discovered Primo kneeling before Crysthel in her bedroom with his pants down, “forcing his penis into Crysthel’s vagina.” She shouted, wrestled him, and called relatives, who apprehended him until barangay officials arrived. A medico-legal examination revealed an intact hymen, a 0.5 cm vaginal orifice, and no extra-genital injuries. At the Court of First Instance in Malabon (RTC-Br. 170, Crim. Case No. 16857-MN), Judge Benjamin T. Antonio found Primo guilty of statutory rape under Article 335(3) of the Revised Penal Code as amended by R.A. 7659, imposed the death penalty, and awarded damages. Primo maintained his innocence, insiste Case Digest (G.R. No. 206958) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- On 25 April 1996 at around 4:00 PM, Ma. Corazon P. Pamintuan left her four-year-old daughter Crysthel upstairs to prepare Milo drinks downstairs.
- Primo Campuhan y Bello, helper of Corazon’s brother, was in the house filling plastic bags with water for ice.
- Alleged incident
- Corazon heard Crysthel cry “Ayoko, ayoko!” and rushed upstairs to find Primo kneeling before the child with his short pants down and the child’s underwear removed.
- She saw Primo forcing his penis into Crysthel’s vagina, boxed him several times, and called relatives who detained him until barangay officials intervened.
- Medical and trial proceedings
- A medico-legal examination showed Crysthel’s hymen intact with a 0.5 cm orifice and no extra-genital injuries.
- Primo denied the charge, claiming the child slipped on him during play and that the accusation was fabricated.
- The trial court convicted him of statutory rape under Art. 335(3) of the RPC as amended by RA 7659, imposing the death penalty and ordering damages.
- Supreme Court review
- The case reached the Supreme Court on automatic review of the death penalty under RA 7659.
- Central to review was whether the evidence proved consummated rape or only attempted rape.
Issues:
- Whether the prosecution proved carnal knowledge by penetration into the labia or lips of the minor’s genitalia.
- Whether the combined testimony and medical findings suffice to uphold a statutory rape conviction warranting death.
- Whether reasonable doubt and presumption of innocence require reclassification to attempted rape.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)