Case Digest (G.R. No. 143704)
Facts:
People of the Philippines v. Alex Manallo, G.R. No. 143704, March 28, 2003, Supreme Court Second Division, Callejo, Sr., J., writing for the Court.The victim, AAA, a nine‑year‑old daughter of spouses xxx x and xxxx, washed clothes at a barangay reservoir on the morning of March 30, 1992 and walked home along an uninhabited grassy path that normally took about fifteen minutes. On that route she was accosted by Alex Manallo, a coconut gatherer engaged by AAA’s parents, who allegedly emerged from the bushes completely naked, grabbed her from behind, covered her mouth, threatened her with a knife, dragged her to a grassy area, struck her, rendered her unconscious and sexually assaulted her. When AAA regained consciousness she found herself naked, felt aching and weak, and noticed semen in her vagina; she ran home and promptly told her mother, after which they reported the incident to barangay officials and to the police.
The victim was examined at the Rural Health Unit by Dr. Ma. Crispa Loria‑Florece at about 12:15 p.m. the same day; the medico‑legal certificate recorded a contusion on the right cheek, a hematoma on the right thigh, fresh bleeding hymenal lacerations at multiple clock positions and motile sperm cells on vaginal smear. An information for rape under Article 335(1) of the Revised Penal Code was filed in the Regional Trial Court (Legaspi City) on April 27, 1992.
On May 8, 1992, Manallo moved for bail; the Executive Judge granted bail the same day and fixed a P50,000 bond, which was posted and approved; Manallo was released. At arraignment on June 17, 1992 he pleaded not guilty; the prosecution moved for cancellation of the bond on the ground that the bail was granted without hearing, but the trial court deferred resolution and allowed Manallo to remain free until the set bail hearing. Manallo failed to appear at the June 22, 1992 hearing and went into hiding; he eluded arrest for about six years and was finally apprehended on January 22, 1998.
At trial Manallo testified that he and AAA had an ongoing consensual sexual relationship since 1991 (the so‑called “sweetheart” defense) and that AAA had solicited money from him; his wife testified that he admitted the act to her and instructed her to seek forgiveness or a settlement with AAA’s mother. The trial court (Judge Vladimir B. Brusola) found AAA’s testimony and the medico‑legal evidence credible and convicting, noting also Manallo’s flight and escape from bail. By decision dated April 25, 2000 the RTC found Manallo guilty beyond reasonable doubt of rape and sentenced him to reclusio...(Subscriber-Only)
Issues:
- Did the trial court err in granting bail to appellant without a proper hearing under the Rules of Court and, if so, did that procedural lapse fatally undermine the prosecution’s case?
- Was the evidence presented by the prosecution sufficient to convict appellant beyond reasonable doubt for rape under Article 335 of the Revised Penal Code?
- Did appellant’s claim of a consensual "sweetheart" relationship with the victim negate the elements of rape or otherwise create reasonable doubt?
- Were the awards of civil indemnity, moral ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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