Case Digest (G.R. No. 9274)
Facts:
The People of the Philippines v. Mario Guillermo y Esteban, G.R. No. 173787, April 23, 2007, the Supreme Court En Banc, Garcia, J., writing for the Court. The respondent in the criminal prosecution is Mario Guillermo y Esteban (accused-appellant); the People of the Philippines is the plaintiff-appellee. The case concerns two separate Informations charging appellant, his daughter being the victim, with incestuous rape.Appellant was charged in two Informations (Criminal Case Nos. 2001-129 and 2001-130) for having, on November 18, 2000 and April 29, 2001 respectively, unlawfully had sexual intercourse with his daughter, then 14 years old, by force, threats and intimidation. He pleaded not guilty at arraignment on March 12, 2002. The prosecution presented the victim’s testimony, the mother’s testimony, and the medico-legal examination by Dr. Mercedes Gapultos; the defense relied principally on appellant’s denial and an assertion that the victim was coached by her mother.
On February 5, 2004, the Regional Trial Court (RTC), Branch 68, Camiling, Tarlac, convicted appellant of two counts of rape under Article 266-A of the Revised Penal Code, as amended, and sentenced him to death for each count, with awards of civil indemnity, moral and exemplary damages. Pursuant to this Court’s ruling in People v. Mateo, the case was referred to the Court of Appeals (CA) for appropriate action and docketed as CA-G.R. CR-H.C. No. 00103. In its April 6, 2006 decision, the CA affirmed the RTC’s conviction and sentences (including death), and ordered the records forwarded to the Supreme Court after the period for motions for reconsideration.
This Court, by Resolution of September 19, 2006, accepted the case for automatic review and required supplemental briefs; both parties adopted their CA briefs. The appeal raised, inter alia, that (1) the fact of carnal knowledge was not proven with certainty and (2) the prosecution failed to prove the victim’s real age so as to justify imposition of the death penalty. The CA and RTC credited the victim’s testimony, the medico-legal report showing healed hymenal lacerations, and documentary proof of the victim’...(Subscriber-Only)
Issues:
- Was the prosecution able to prove beyond reasonable doubt the elements of incestuous rape (including carnal knowledge and identification of the perpetrator)?
- Was the imposition of the death penalty proper in this case, and if not, what penalty should be imposed given the passage of R.A. No. 9346?
- Were the awards of civil indemnity, moral and exemplary damages a...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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