Case Digest (G.R. No. 168168)
Facts:
People of the Philippines v. Edgardo Dimaano, G.R. No. 168168, September 14, 2005, the Supreme Court En Banc, Per Curiam. The appellant is Edgardo Dimaano; the People is the appellee.On January 26, 1996 Maricar Dimaano (the complainant) filed three criminal informations against her father, Edgardo Dimaano: Criminal Case No. 96‑125 (rape allegedly committed in September 1993 when she was about ten), Criminal Case No. 96‑150 (rape on December 29, 1995, when she was 12), and Criminal Case No. 96‑151 (attempted rape on January 1, 1996). Appellant pleaded not guilty and the cases proceeded to trial before the Regional Trial Court (RTC), Branch 257, Paranaque City.
At trial the complainant, who was born August 26, 1983, testified in detail about repeated sexual assaults by her father in 1993, late 1995 and on January 1, 1996. A medico‑legal examination showed deep healed hymenal lacerations and a “non‑virgin” state. Appellant denied the charges, offered alibi and argued that the complainant might have had intercourse with another person; he also pointed to occasions when the complainant accompanied him to public offices as inconsistent with the alleged abuse.
The RTC found the complainant credible, rejected the Compromise Agreement and the affidavit of desistance, and convicted appellant of two counts of rape and one count of attempted rape, imposing reclusion perpetua for the first rape, death for the second (December 29, 1995), and an indeterminate term for attempted rape; the court also ordered indemnity and exemplary damages. The Court of Appeals (CA) affirmed with modifications (separating and increasing the damage awards) and, pursuant to Sec. 13, Rule 124 of the Amended Rules to Govern Review of Death Penalty Cases, certified the case to the Supreme Court for review. Appellant raised (among...(Pro-only)
Issues:
- Did the prosecution’s evidence overcome the presumption of innocence and prove appellant’s guilt beyond reasonable doubt for the rape charges?
- Should the complainant’s affidavit of desistance and the Compromise Agreement have cast doubt sufficient to dismiss or weaken the prosecution?
- Was the information in Criminal Case No. 96‑151 suffici...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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