G.R. No. 150613-14 - People vs. Mantis

The accused, Manuel Mantis, was charged in two separate informations filed on August 25, 1999, by the Office of the Provincial Prosecutor of Pampanga.
The charges involved two counts of rape committed against Mary Jane L. Balbin, a minor.
Criminal Case No. G-4788 charged the accused with raping Mary Jane on April 3, 1999, while Criminal Case No. G-4797 charged him with a similar act on July 16, 1998.

Mary Jane L. Balbin, the victim, is the daughter of the common-law spouse of the accused and had known him since she was six years old, growing up considering him a father figure.
The familial and domestic setting was such that Mary Jane lived with her mother, siblings, and the accused in a three-bedroom house at Valdez, Floridablanca, Pampanga.
The close and trusted relationship between the accused and the victim created an environment that the accused would later allegedly exploit.

Mary Jane was brought home from a hospital visit by her godfather and later fetched by the accused.
While she was preparing for bed, the accused entered her room wearing only a t-shirt, removed her clothing, and, using force, threatened her with death if she resisted or reported his act.
Despite her attempts to free herself, the use of force and intimidation coerced her into submission.

While Mary Jane was asleep in her room with her two sisters, the accused entered the room, again stripped her, and forcibly committed the act.
Mary Jane, though struggling to resist, was overpowered by the accused, and the threat of harm to her and her mother silenced her.

Mary Jane testified about the incidents in detail in open court, including her inability to resist due to the accused’s tight hold and death threats.
Medical evidence was presented by Dr. Grace Salinas, who, via physical and ultrasound examinations, confirmed injuries consistent with rape and established that Mary Jane was pregnant, indicating prior occurrences of abuse.
A photocopy of Mary Jane’s Certificate of Live Birth was introduced to support her age, though its authenticity later became a critical evidentiary point.

Manuel Mantis, with the assistance of counsel, pleaded not guilty and raised defenses of denial, alibi, and, eventually, an assertion that the alleged acts were consensual.
He contended he had an alibi on both dates (claiming to be at the hospital during the 1998 incident and at his employer’s office on the 1999 incident) and suggested that any sexual encounter was consensual despite the inherent power imbalance due to his role in the victim’s life.
He attempted to shift the explanation by portraying the victim as of loose character, hinting that her pregnancy could have resulted from relations with other individuals.

The Regional Trial Court of Guagua, Pampanga, Branch 52, found the accused guilty beyond reasonable doubt of two counts of rape.
The Court sentenced Manuel Mantis to death for each count and ordered him to pay civil indemnity and moral damages to the victim.
In its finding, the trial court gave significant weight to the victim’s consistent testimony and the corroborative, albeit partly disputed, documentary and medical evidence.
The records, including stenographic transcripts, were forwarded to the Supreme Court for automatic review under the applicable rules.

Whether the prosecution presented evidence that proved the accused’s guilt of raping the minor beyond reasonable doubt.
Whether the victim’s testimony—despite her delayed reporting and the circumstances surrounding her recollection—was credible and corroborated by independent evidence.
Whether the use of force, threat, and intimidation was adequately demonstrated, particularly in light of the accused’s contention that the act was consensual.

Whether the imposition of the death penalty was proper when the information did not specify with sufficient clarity the qualifying circumstances regarding the victim’s age and relationship to the accused.
Whether the evidentiary shortcomings—specifically the reliance on a photocopy of the victim’s birth certificate—warranted a mitigation of the harsh penalty imposed by the trial court.
Whether the awards for civil indemnity and moral damages, as well as the introduction of exemplary damages, were appropriate in light of the circumstances and current jurisprudence.