Title
People vs. Ison
Case
G.R. No. 62806
Decision Date
May 5, 1989
A 13-year-old girl was raped by her distant uncle during a trip; the Supreme Court upheld his conviction, citing credible testimony and medical evidence.

Case Digest (G.R. No. 62806)

Facts:

People of the Philippines v. Danilo Ison @ Danny, G.R. No. 62806, May 05, 1989, Supreme Court Second Division, Melencio-Herrera, J., writing for the Court.

The criminal action arose from a complaint filed by Leonila P. Santiago (the offended party), a 13‑year‑old girl, alleging that on 17 April 1979 she was raped by her distant uncle, Danilo Ison (the accused-appellant), during a trip from Barrio Lambaken, Jaen, Nueva Ecija to Roxas, Isabela. The accused normally traveled with his helper, Alfredo Lozada. According to the complaint, the three rode in the front of a jeep filled with egg boxes; they slept at a diversion road near the Echague cemetery; Leonila was awakened, struggled, was struck on the abdomen, rendered unconscious and later found to have been sexually violated; the accused allegedly threatened her to keep silent. Leonila mailed a letter to her mother recounting the incident and, upon return, the mother caused a complaint to be filed on 7 May 1979 with the Municipal Court of Echague, Isabela.

An Information was filed in the Court of First Instance (CFI) of Isabela charging the accused with rape. Trial ensued and, on 7 June 1982, the CFI (decision penned by Judge Procoro J. Donato) found the accused guilty beyond reasonable doubt under Article 335 of the Revised Penal Code (as amended) and sentenced him to reclusion perpetua, ordered moral indemnity of P12,000 and other penalties. The accused appealed to the Supreme Court, urging (1) physical impossibility/improbability that the incident occurred at the alleged place and time given distance and road conditions; (2) that the complainant's story was utterly incredible; and (3) that the conviction should be set aside.

The Supreme Court resolved the appeal by affirming the convictio...(Subscriber-Only)

Issues:

  • Was it physically impossible or so improbable that the accused was at the alleged scene and time of the rape as to warrant acquittal?
  • Was the complainant’s testimony utterly incredible so that it should not be believed?
  • Should the conviction for rape be re...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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