Case Digest (G.R. No. 97441)
Facts:
People of the Philippines, Plaintiff-Appellee, vs. Domingo Casinillo, Accused-Appellant, G.R. No. 97441, September 11, 1992, the Supreme Court Third Division, Davide, Jr., J., writing for the Court.The prosecution arose from a complaint for rape dated 17 May 1989 filed by Leticia Soria before the Municipal Trial Court of Mati, Davao Oriental. After preliminary investigation the municipal court found reasonable ground to hold the accused for trial, and on 12 July 1989 the Provincial Prosecutor filed Information in RTC Branch 6 (Mati) Criminal Case No. 1847 charging Domingo Casinillo with rape under Article 335, as amended, of the Revised Penal Code; two separate Informations (Crim. Cases Nos. 1844 and 1845) for robbery with rape and robbery in band were likewise filed against Casinillo and three co-accused.
On 8 August 1989 the accused entered pleas of not guilty; the three cases were tried jointly. In its 22 October 1990 decision the RTC acquitted all accused in Crim. Cases Nos. 1844 and 1845 but convicted appellant in Crim. Case No. 1847 for rape and sentenced him to reclusion perpetua, ordered payment of P20,000 and P10,000 as moral damages and attorney’s fees respectively, and imposed costs. The trial court credited the victim’s eyewitness identification and rejected the appellant’s denial and alibi.
Appellant filed a Notice of Appeal on 25 October 1990. His principal contentions before the Court were that the victim did not positively identify him (pointing to police blotter entries indicating masked assailants), that police lineups were conducted without counsel and in violation of constitutional rights, that crucial witnesses (P/Sgt. Arnold Malintad and Barangay Captain Patricio Cabingatan) were not presented by the prosecution, and that his alibi—corroborated by his wife and father—should have raised reasonable doubt. The prosecution relied on the victim’s detailed testimony, three police lineups, and a medical certificate showing hymenal laceration and thigh contusions.
The Supreme Court reviewed the RTC’s factual findings and the ...(Subscriber-Only)
Issues:
- Did compelling the accused to participate in police lineups without counsel violate his constitutional rights so as to require exclusion or reversal?
- Did the prosecution suppress material evidence by not presenting P/Sgt. Arnold Malintad and Barangay Captain Patricio Cabingatan under Section 3(e), Rule 131, Rules of Court?
- Was the appellant proven guilty beyond reasonable doubt—specifically, was the victim’s identification of the appellant sufficiently positive and credible?
- Was the appellant’s alibi, corroborated only by his wif...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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