Case Digest (G.R. No. L-38309)
Facts:
The People of the Philippines v. Angelito de Jesus, G.R. No. L-38309, October 23, 1978, the Supreme Court Second Division, Aquino, J., writing for the Court. The plaintiff-appellee was The People of the Philippines; the defendant-appellant was Angelito de Jesus.On the night of the Flores de Mayo procession, May 21–22, 1972, nine-year-old Lualhati Landayan went with a neighbor, Josie Garcia, to the barrio chapel in Barrio Santol, Balagtas, Bulacan. Josie left Lualhati asleep on a bench in the chapel to watch a basketball game; sometime after midnight Lualhati awoke to find herself on a haystack about fifty meters from the chapel with a man on top of her. She pushed him, felt his mustache, was struck unconscious, and later awoke to pain and bleeding; the man warned her not to tell anyone. She returned to the chapel, could not find Josie, and later went home with other children.
Lualhati was examined by Dr. Mario Puatu who noted bleeding lacerations of the hymen and facial injuries. Subsequent examinations by the municipal health officer, Dr. Roberta S. Regalado, and by NBI medico-legal officer Dr. Nieto M. Salvador (living case report, Exh. G) documented hymenal lacerations, contusions, bits of hay in the labia majora, and other injuries consistent with sexual assault. Lualhati was hospitalized from May 23 and her mother incurred P165 in expenses.
Feliciana Landayan reported the assault to police on May 22; investigation by Lieutenant Leonardo B. Feliciano produced witness statements, including that of nine-year-old Florante Dizon who said he saw a man in the chapel wearing red pants. The police detained three suspects, including De Jesus. Confrontations arranged May 30 resulted in Lualhati twice identifying De Jesus as her assailant; during preliminary inquiry De Jesus’s red pants were shown to Lualhati and identified as those worn by the man at the haystack. A municipal judge found reasonable ground to believe rape had been committed and issued an arrest warrant (June 8, 1972); De Jesus posted bail June 9, 1972.
An information for rape was filed in the Court of First Instance (provincial fiscal filed information August 9, 1972). After trial the Court of First Instance of Bulacan convicted De Jesus of rape, sentenced him to life imprisonment, and ordered indemnity of P165. De Jesus appealed to the Supreme Court. In the course of proceedings the prosecution introduced a confessi...(Pro-only)
Issues:
- Was appellant’s guilt established beyond reasonable doubt, i.e., was the nine‑year‑old victim’s identification and the prosecution’s evidence sufficiently credible to convict?
- Was the NBI confession (Exh. H) admissible and properly used to corroborate the prosecution’s case?
- Was the trial court’s penalty and award of indemnity proper, or should the indemnity and the characteriz...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)