Case Digest (G.R. No. 187495)
Facts:
People of the Philippines v. Edgar Jumawan, G.R. No. 187495, April 21, 2014, the Supreme Court First Division, Reyes, J., writing for the Court. The criminal case arose from two informations, each for rape, filed in the Regional Trial Court (RTC) of Cagayan de Oro City after the Office of the City Prosecutor found probable cause. The victim, identified in the records as KKK, alleged that her husband, Edgar Jumawan (accused-appellant), raped her on the nights of October 16 and October 17, 1998. The informations were originally dated with different alleged dates; the prosecution later moved to amend the informations to reflect the true name of the complainant and the corrected dates, which the trial court granted and the accused was re-arraigned. The accused pleaded not guilty and a joint trial followed.At the RTC, the prosecution relied principally on the testimony of KKK and corroborative testimony of their daughters (MMM and OOO), plus torn underwear admitted as physical evidence. The defense presented an alibi supported by the spouses' driver and advanced theories of fabrication motivated by marital and business disputes, and alleged extra‑marital affairs by the wife. After trial, the RTC (Judge Anthony E. Santos) found the victim and her daughters credible, rejected the accused’s alibi and motive theories, convicted the accused of two counts of rape, sentenced him to reclusion perpetua for each count, and awarded damages (Judgment dated April 1, 2002).
The Court of Appeals (CA) in CA‑G.R. CR‑HC No. 00353 affirmed the RTC decision in a Decision dated July 9, 2008, holding among other things that the amendment of the informations was proper under Section 14, Rule 110 of the Rules of Criminal Procedure, the victim’s testimony and her daughters’ corroboration established force and intimidation under R.A. No. 8353 (the Anti‑Rape Law of 199...(Subscriber-Only)
Issues:
- Was the amendment of the original informations prejudicial to the accused?
- Does marriage bar prosecution for rape — i.e., can a husband be criminally liable for raping his wife under R.A. No. 8353?
- Did the prosecution prove beyond reasonable doubt that the accused committed rape on October 16 and 17, 1998 (absence of consent by force, threat or intimidation; sufficiency and corroboration of evidence)?
- Are the penalties and damages imposed by the lower courts proper (including parole ineligibility and amount...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)