Case Digest (G.R. No. 175592)
Facts:
People of the Philippines v. Edison C. Magbitang, G.R. No. 175592, June 14, 2016, Supreme Court En Banc, Bersamin, J., writing for the Court.The prosecution charged Edison C. Magbitang (accused-appellant) by information filed February 22, 1999 in the Regional Trial Court (RTC) of Guimba, Nueva Ecija, with the composite crime of rape with homicide for acts allegedly committed on December 25, 1998 against a seven‑year‑old girl identified in the records by the initial AAA. The information alleged that Magbitang, taking advantage of AAA’s tender age, raped and thereafter strangled her to death.
On the evening of December 25, 1998, AAA left home to go to a nearby store and did not return; her lifeless body was later found at a riverbank. The medico‑legal report stated that AAA died of asphyxiation and bore “incidental findings compatible to rape.” The lone eyewitness was six‑year‑old CCC, who testified that he saw Magbitang take AAA to his house and, on redirect, recounted witnessing Magbitang rape AAA and burn her face with a cigarette. Magbitang denied the charges and offered an alibi that he attended a baptismal party and thereafter was at his farm with his wife and nephew.
The RTC convicted Magbitang on April 22, 2003 of rape with homicide, sentenced him to death, and awarded P100,000.00 actual and P50,000.00 moral damages to the victim’s heirs. The Court of Appeals (CA) affirmed the conviction, finding CCC competent despite his tender age, concluding that CCC positively identified ...(Subscriber-Only)
Issues:
- Was the six‑year‑old witness CCC competent and worthy of belief such that his testimony could sustain conviction?
- Was the guilt of the accused proven beyond reasonable doubt to support conviction for rape with homicide?
- Could the conviction be sustained on the combination of direct testimony from a child witness an...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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