Case Digest (G.R. No. 72355-59)
Facts:
People of the Philippines v. Juan P. David, G.R. Nos. 72355-59, September 15, 1989, Supreme Court Third Division, Gutierrez, Jr., J., writing for the Court. The appellant, Juan P. David, was charged in five separate criminal complaints before the Regional Trial Court (RTC) of Quezon City, Branch 106, for rape: one count (Crim. Case No. Q-20893) alleging carnal knowledge of six‑year‑old Ma. Theresa Aguilar in May 1982; and four counts (Crim. Cases Nos. Q-20894–97) alleging rape of household maid Luz Delgado at various times in April–May 1982. The trial court convicted David on all five counts, imposing reclusion perpetua and P30,000 indemnity for each count.The prosecution presented testimony from members of the Aguilar household (Adelaida, Toribia), the maid Luz, the child Theresa, and medical examiners. Evidence established that David lived with Adelaida and the Aguilar family; Adelaida observed suspicious touching of young Theresa on prior occasions. Luz recounted four separate incidents in which David locked her in his bedroom, displayed pornographic photos, threatened her with an eight‑inch knife, and raped her; she testified to physical pain and bleeding, but delayed reporting out of fear. Theresa, then six, described being made to lie down, having her panty removed, and experiencing pain from contact with David’s penis; she did not show hymenal penetration but a medico‑legal report noted congestion and redness of the vulvar area possibly caused by an attempt to force penetration. Medico‑legal findings: Theresa’s smears were negative for spermatozoa and she remained physically a virgin but with vulvar congestion (PC-CIS report); Luz had healed lacerations consistent with multiple acts and was found not to be a virgin, smears likewise negative.
David denied all allegations, contending fabrication by the family to separate him from Adelaida, suggesting Luz had an affair with the houseboy, and arguing Theresa’s account was a product of exposure to pornography. He also challenged the consolidation of the ...(Subscriber-Only)
Issues:
- Did consolidation of the five separate rape complaints for joint trial prejudice the accused’s rights?
- Did the prosecution prove beyond reasonable doubt the elements of rape as to Luz Delgado (force or intimidation and carnal knowledge)?
- Did the prosecution prove beyond reasonable doubt the elements of rape as to Ma. Theresa Aguilar (carnal knowledge of a...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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