Case Digest (G.R. No. 177766)
Case Digest (G.R. No. 177766)
Facts:
The case is People of the Philippines v. Claro Jampas y Luana, G.R. No. 177766, July 17, 2009, Supreme Court Second Division, Carpio Morales, J., writing for the Court. The appellant is Claro Jampas y Luana; the appellee is the People of the Philippines. The minor victim is referred to as AAA (name withheld).In a complaint dated September 27, 2001 filed with the Municipal Trial Court (MTC) of Naval, Biliran, AAA charged appellant with having raped her several times during 1999 and 2000. After preliminary investigation, an Information was filed on May 13, 2002 charging appellant with rape allegedly committed in the mid-year of 1999 at about 11:00 a.m.; the Information also alleged aggravating circumstances (that the accused was her uncle and that the victim was under twelve years of age).
At the Regional Trial Court (RTC), Branch 16, Naval, Biliran, the prosecution presented the testimony of AAA (who was eight at the time of the alleged incident) and Dr. Josephine Dayoha, who examined AAA on September 21, 2001 and found healed incomplete hymenal lacerations. Appellant denied the charge, presenting an alibi that he was in Manila from June 1999 until February 2000, supported by testimony from his common-law wife and witnesses. The RTC rendered judgment on April 13, 2004 convicting appellant of rape and imposing reclusion perpetua, and awarding moral and civil damages to AAA.
Pursuant to People v. Mateo and the Court’s resolution, the case was referred to the Court of Appeals (CA). By Decision dated August 10, 2006, the CA affirmed the RTC conviction. Appellant then filed the present petition for review on certiorari with the Supreme Court (Rule 45), adopting his CA brief; both parties dispensed with supplemental briefs. Appellant raised, inter alia, that the Information was fatally defective for failure to state the precise date, that the prosecution failed to prove guilt beyond reasonable doubt, and that his defense (alibi) was not properly considered by the lower courts.
Issues:
- Was the Information fatally defective for failing to state the precise date of the alleged rape?
- Did the prosecution prove the guilt of appellant beyond reasonable doubt?
- Did the trial and appellate courts fail to consider or give due weight to appellant’s defense (alibi)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)