Case Digest (G.R. No. 135022)
Facts:
People of the Philippines v. Bienvenido Dela Cruz, G.R. No. 135022, July 11, 2002, First Division, Davide, Jr., C.J., writing for the Court (Vitug, Kapunan, Ynares‑Santiago, and Austria‑Martinez, JJ., concurring).The case arose from two informations filed by the Provincial Prosecutor before the Regional Trial Court (RTC) of Malolos, Bulacan, following a complaint dated July 5, 1996, signed by Jonalyn Yumang (the offended party) with the assistance of her aunt. The informations were docketed as Criminal Cases Nos. 1274‑M‑96 and 1275‑M‑96; the appeal now concerns Criminal Case No. 1275‑M‑96, which charged Bienvenido Dela Cruz (accused‑appellant) with rape allegedly committed on July 3 and 4, 1996. At arraignment on October 14, 1996, the accused pleaded not guilty; the two cases were consolidated for trial.
Because the prosecution perceived that Jonalyn had difficulty expressing herself, the trial court allowed a psychiatric examination. Dr. Cecilia Tuazon of the National Center for Mental Health examined Jonalyn on July 12, 1996 and testified that Jonalyn had moderate mental retardation and a mental age comparable to a young child (the trial court described her mental age as that of an eight‑year‑old). The trial court granted the prosecution leave to propound leading questions under Section 10(c), Rule 132, Rules on Evidence. On direct and leading examination Jonalyn identified the accused as “Jun‑Jun,” testified that the accused raped her twice inside a house, and described penile penetration; a medico‑legal examination by Dr. Edgardo Gueco showed fresh and healing hymenal lacerations consistent with recent forcible defloration.
After the prosecution rested, the defense filed a demurrer to evidence asserting, among other things, that the trial court lacked jurisdiction because Jonalyn—by reason of mental deficiency—was incompetent to sign the complaint and to prosecute the action, and that her testimony was coached and unreliable. The trial court denied the demurrer, the accused later moved for judgment and submitted the case without presenting defense evidence, and in a joint decision dated April 3, 1998 the RTC convicted the accused in Criminal Case No. 1275‑M‑96 (sentencing him to reclusion perpetua and ordering P60,000 civil indemnity) and acquitted him in Criminal Case No. 1274‑M‑96 for insufficiency of evidence.
The accused ...(Subscriber-Only)
Issues:
- Was the criminal complaint filed by Jonalyn valid such that the trial court had jurisdiction to try the case?
- Was Jonalyn competent to testify at trial despite her mental retardation?
- Was Jonalyn’s testimony credible and sufficiently corroborated?
- Was it proper to permit the prosecution to propound leading questions to Jonalyn?
- Was the prosecution’s evidence sufficient to sustain a conviction for...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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