G.R. No. L-23996 - Pacis vs. Pamaran

Accused-appellants Donel Go and Val de los Reyes were charged with multiple counts of rape committed against Imelda Brutas.
At the outset, Donel Go was apprehended and arraigned on May 3, 1995, while Val de los Reyes remained at large.
The prosecution’s evidence included the testimonies of five witnesses (private complainant Imelda Brutas, her mother Adela, her sister Clara, Dr. Marissa Saguinsin of the Rural Health Unit in Tabaco, Albay, and SPO4 Rosalino Bonavente), physical items (such as the panty and watch worn by Imelda during the alleged incident), medical certificates, certification of the police blotter entry of the complaint, affidavits, photographs, and a referral form from an ABS-CBN program.

The RTC of Tabaco, Albay, Branch 16, tried the case against Donel Go in his absence after he jumped bail and found him guilty beyond reasonable doubt on two counts of rape.
An alias warrant was issued against Val de los Reyes, and although his case was initially archived, it was later revived and transferred to Branch 15—designated as a heinous crimes court—once he was apprehended.
During the trial of Val de los Reyes, he pleaded not guilty to all three charges of rape, and evidence from the earlier trial (transcripts, exhibits, and prior testimonies) was reintroduced by the prosecution.

The prosecution sought to introduce prior testimony by calling witnesses (Adela, Clara, Imelda, and Dr. Saguinsin) to affirm the same answers they had given at the trial of Donel Go.
The method involved the private prosecutor reading out the transcript of the witnesses’ previous testimonies, expecting them to confirm their earlier statements rather than providing a fresh oral account.
Defense counsel objected on the ground that such an abbreviated procedure deprived the accused of the right to confront and cross-examine the witnesses on their current testimony.

The prosecution introduced several exhibits, including physical items (the panty and wristwatch), official certifications, medical certificates, and transcripts of previous testimonies, to establish the occurrence of the alleged rapes.
The defense raised objections to the admission of certain exhibits and the method of re-adopting the transcript testimony, arguing that this method failed to properly identify and authenticate the evidence, particularly since Val de los Reyes was not a party to the original proceedings.

Accused-appellant Val de los Reyes contended that the trial court abused its discretion by allowing a summary proceeding instead of a full, fair trial with fresh testimony.
He further argued that convicting him based on evidence derived from previous procedures, without proper cross-examination, violated his constitutional right to due process.
Accused-appellant Donel Go also raised issues, specifically concerning the weight given by the trial court to the testimony of the private complainant.

Whether the trial court erred in allowing the prosecution to have witnesses simply affirm their previous testimony from the trial of accused-appellant Go.

Was the accused’s right to confront and cross-examine the witnesses violated by re-adopting their earlier transcript testimony?

Whether the admission of non-identified exhibits and the adoption of a summary trial procedure deprived the accused of due process.

Did the abbreviated procedure and the lack of a fresh oral testimony amount to an abuse of the trial court’s discretion?

Whether the reliance on evidence from prior proceedings—particularly the weight given to the private complainant’s testimony—is sufficient to support a conviction beyond reasonable doubt.

Was the evidentiary basis for convicting the accused properly established given the procedural irregularities presented?