Case Digest (G.R. No. 113250-52)
Facts:
People of the Philippines v. Teotimo Magpantay, G.R. Nos. 113250-52, January 14, 1998, Supreme Court Third Division, Melo, J., writing for the Court.The appellant is Teotimo Magpantay (accused-appellant); the prosecution is the People of the Philippines; the alleged victim is his then 15‑year‑old daughter Ronalyn Magpantay y Montales, and her mother is Estrella Montales Magpantay. Three separate Informations charged the accused with three counts of rape occurring in May, June 1991 (specifically June 28), and July 3, 1991 in Tanay, Rizal (Crim. Cases Nos. 1152‑M, 1153‑M and 1154‑M). At arraignment on September 1, 1992, the accused pleaded not guilty.
At the joint trial the prosecution presented the victim, her mother (who purportedly witnessed the June 28 incident), the victim’s brother Michael (who purportedly saw the July 3 incident), and Dr. Vladimir E. Villasenor of the PNP Laboratory Service, who testified to healed lacerations on the victim’s genitalia (noted at “9:00 o’clock, 3:00 o’clock, 5:00 o’clock, and 6:00 o’clock,” Exhibit C). The prosecution’s theory recounted repeated sexual assaults, committed with a knife to the victim’s neck and accompanied by threats to kill her if she told anyone.
The Regional Trial Court, Fourth Judicial Region, Branch 79 (Morong, Rizal) found the victim’s account credible, relied on her demeanor and corroboration by her mother and brother and the medico‑legal findings, and on October 22, 1993 rendered judgment convicting the accused in each case and sentencing him to reclusion perpetua and to pay P50,000 indemnity in each case.
The accused filed a Notice of Appeal on November 16, 1993. The lower court ordered elevation of the record but some stenographic transcripts had been destroyed in a courtroom fire; the court thus retook testimony to complete the record. The transcripts were completed October 16, 1996. The accused filed his brief March 14, 1997; the People filed their brief October 15, 1997. The accused assigned a single error on “alibi” but chiefly attacked the credibility of the victim’s mother and the expert without establishing the technical requisites of...(Subscriber-Only)
Issues:
- Was the accused’s asserted alibi (and the alternative contention that the victim’s mother instigated a false accusation) sufficiently established to warrant reversal of the convictions?
- Did the trial court err in assessing witness credibility and in finding the evidence sufficient to suppor...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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