Case Digest (G.R. No. 115908-09) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Danny Godoy, G.R. Nos. 115908-09, decided December 6, 1995 under the 1987 Constitution, the accused-appellant Danny Godoy, a married Physics teacher at Palawan National School, was charged in two separate informations with (a) rape under Article 335 of the Revised Penal Code as amended by Republic Act No. 7659 (Criminal Case No. 11640) and (b) kidnapping with serious illegal detention under Article 267 of the same Code as amended (Criminal Case No. 11641). The complainant, 17-year-old Mia Taha, alleged that on the evening of January 21, 1994, Godoy forcibly raped her at her cousin’s boarding house in Brooke’s Point, Palawan, threatening her with a knife; the next day he purportedly induced her parents to allow her to solicit funds with him but then detained and raped her repeatedly over five days at the Sunset Garden hotel and at a friend’s house in Edward’s Subdivision. A medico-legal examination noted a week-old hymenal laceration but no externa... Case Digest (G.R. No. 115908-09) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- Two separate informations were filed against accused‐appellant Danny (Dane) Godoy before the Regional Trial Court of Palawan, Branch 47:
- Criminal Case No. 11640 for rape under Article 335, RPC.
- Criminal Case No. 11641 for kidnapping with serious illegal detention under Article 267, RPC.
- Appellant pleaded not guilty to both charges. After pre‐trial, a joint trial was held. The trial court convicted him of both crimes and imposed the death penalty. Pursuant to Republic Act No. 7659, the cases were elevated on automatic review to the Supreme Court.
- Prosecution’s Evidence
- Complainant’s Testimony (Mia Taha)
- January 21, 1994: Alleged rape at her cousin’s boarding house in Brooke’s Point. Appellant, her Physics teacher, grabbed her at knifepoint, dragged her into a dark kitchen, forced her to lie on the floor, removed her clothing, and had carnal knowledge of her against her will. She claimed she could not shout or fight back due to fear and threats to kill her family.
- January 22–27, 1994: Alleged kidnapping and serious illegal detention. Appellant allegedly obtained her parents’ permission to “solicit funds” the next day, then forced her into a jeep, brought her to Sunset Garden where she was repeatedly raped and locked in a room for three days, and later to Edward’s Subdivision for further rape. She was released only after her parents agreed to a settlement.
- Medical Examination
- Dr. Rogelio Divinagracia found a stellate hymenal laceration, approximately ½ cm long at the fossa navicularis—healed and about a week old. No extra-genital injuries, bruises or scratches were noted.
- Corroborating Witnesses & Proceedings
- Helen Taha (mother) testified on her daughter’s demeanor, the filing of complaints with PNP/NBI, and settlement negotiations.
- Adjeril and Helen Taha executed an affidavit of desistance as to kidnapping.
- Prosecutor nonetheless filed informations for both rape and kidnapping, with no bail recommended.
- Defense’s Evidence
- Accused’s Version
- Consensual romantic relationship with 17-year-old Mia since December 1993.
- January 21: Met her outside the locked boarding house to discuss a school monologue; sat on a well-lit bench for 15 minutes; no force used.
- January 22–27: Voluntary travel with Mia to Sunset Garden and Edward’s Subdivision to raise funds; no knife threats; voluntary coition admitted on January 24. He sought to involve parents, police and an imam (Naem) for settlement, but not to conceal a crime.
- Defense Witnesses
- Erna Baradero & Filomena Pielago (former teachers) saw appellant and Mia holding hands at night and confirmed Mia’s affectionate letters (Exhs. 1 & 2).
- Fernando Rubio, Benedicto Rubio, and Isagani Virey (hotel and subdivision acquaintances) testified the couple were happy, intimate by mutual consent, unrestrained and free to come and go.
- Letters from Mia to appellant, voluntarily delivered in jail and identified by her handwriting and by defense witnesses, expressed love and plans to escape parental control.
Issues:
- Whether the evidence proved rape beyond reasonable doubt.
- Whether the trial court correctly applied the rape-review doctrine (People vs. Calixto).
- Whether the elements of rape—carnal knowledge by force or intimidation—were established.
- Whether Exhibits “1” and “2” (letters) should have been admitted and credited.
- Whether the evidence proved kidnapping with serious illegal detention beyond reasonable doubt.
- Whether the trial court erred in crediting prosecution witnesses over defense witnesses.
- Whether appellant’s offer to compromise constituted an implied admission of guilt.
- Whether the trial court erred in ordering indemnification of ₱100,000 for each charge.
- Whether the death penalty could be imposed under RA 7659 for crimes allegedly committed before its effectivity.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)