Case Digest (G.R. No. 148056-61)
Facts:
People of the Philippines v. Jose de Castro, G.R. Nos. 148056-61, October 08, 2003, the Supreme Court En Banc, Per Curiam. For automatic review is the consolidated decision of the Regional Trial Court (RTC), Br. 4, Pallocan, Batangas City, in Criminal Cases Nos. 10242–10247, which convicted appellant Jose de Castro of six counts of rape and imposed the death penalty in each case, ordering indemnity of P100,000.00 to each of three complaining witnesses.The factual core is agreed: spouses Jose and Genoveva de Castro had three daughters—Gemma, and twins Jean and Jenny—and two sons. The three daughters, minors at the time, separately accused their father of multiple instances of sexual assault occurring between June 1998 and June 1999 (specific dates appear in the individual Informations: Crim. Case Nos. 10242–10247). Gemma testified to assaults on 3 June 1998 and a subsequent occasion two days later; Jean testified to assaults on 18 April 1999 and 7 June 1999; Jenny testified to assaults on 5 June 1998 and 24 March 1999 and later bore a child (born 3 November 1999), which she attributed to the assaults.
The prosecution presented the victims’ viva voce testimony and medico‑legal examinations by Dr. Janet B. Esguerra showing healed hymenal lacerations and, in Jenny’s case, an enlarged uterus consistent with pregnancy. The defense offered denial and alibi, asserting the accused was selling newspapers or drinking with relatives on the dates alleged. The RTC resolved credibility in favor of the complainants, convicted appellant of six counts of rape, imposed death sentences for each conviction, and ordered P100,000 indemnity to each victim.
Because death sentences were imposed, the judgments were subject to automatic review by the Supreme Court. On review the Court examined testimonial consistency, the victims’ ages and re...(Pro-only)
Issues:
- Whether the prosecution proved appellant’s guilt beyond reasonable doubt in Criminal Cases Nos. 10242–10247.
- Whether the trial court correctly credited the victims’ testimonies and applied the doctrine of moral ascendancy in incestuous rape, despite alleged inconsistencies and opportunities to escape.
- Whether the award of P100,000.00 to each complaining witness sh...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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