Case Digest (G.R. No. L-40330)
Facts:
People of the Philippines v. Amado Daniel alias "Amado Ato," G.R. L-40330, November 20, 1978, Supreme Court En Banc, Munoz Palma, J., writing for the Court. The prosecution charged Amado Daniel (accused-appellant) with rape committed on or about September 20, 1965 in Baguio City against Margarita Paleng (the offended party), then about twelve years and ten months old; the complaint alleged use of a sharp instrument and that the crime was committed in the dwelling of the offended party (aggravating circumstance).The Court of First Instance of Baguio City (presided by Judge Feliciano Belmonte) conducted trial; on May 30, 1966 it found the accused guilty and imposed a sentence described in the record as not more than twelve years and one day of reclusion temporal and not less than six years and one day of prision mayor. The accused's motion for reconsideration and new trial was denied and he appealed to the Court of Appeals.
On September 23, 1974 the Tenth Division of the Court of Appeals (Justice Ricardo C. Puno, ponente) affirmed the finding of guilt but held the sentence imposed by the trial court was not in accordance with law in view of Republic Act No. 4111 (which amended Article 335, Revised Penal Code) and therefore certified the case to the Supreme Court for "appropriate further proceedings" pursuant to the Judiciary Act and Rule 124, Sec. 12 (the court's certification procedure for cases where life or death penalties should be imposed). The case was docketed in this Court by resolution of March 6, 1975.
A preliminary, jurisdictional question arose: whether the Supreme Court could exercise appellate jurisdiction over a criminal case certified by the Court of Appeals that contained findings of guilt but did not itself impose the penalty of reclusion perpetua or death. The bench divided on this point: Chief Justice Castro and some Justices believed the Court of Appeals must have imposed the higher penalty before certification for the Supreme Court to acquire jurisdiction; a majority (including the ponente) held the certificate as rendered was sufficient to vest jurisdiction in the Supreme Court. On the merits, the Supreme Court reviewed the evidence—victim’s testimony, medical (medico-legal) report showing recent defloration and hymenal lacerations, the accused’s claim of consensual intercourse and prior relations, an NBI lie-detector report favorable to accused—and the trial court’s credibility determinations. The Court affirmed convic...(Pro-only)
Issues:
- Does the Supreme Court have jurisdiction to review a criminal case certified by the Court of Appeals that contains findings of guilt but does not itself impose the penalty of reclusion perpetua or death under Rule 124, Sec. 12 and the Judiciary Act?
- Was the accused guilty beyond reasonable doubt of rape as charged, and what is the appropriate ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)