Case Digest (G.R. No. 147678-87) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On October 30, 1996, ten separate informations were filed in the Regional Trial Court (RTC) of Tarlac, Branch 1, against Efren Mateo y Garcia, alleging ten counts of rape committed against his ward and adopted stepdaughter, Imelda C. Mateo, on ten different dates between October 7, 1995 and August 28, 1996, in their house in Barangay Buenavista, Tarlac. Imelda, born September 11, 1980, lived with her mother, Rosemarie Capulong, and appellant since age two. She testified that each time her mother was away—at seminars, work or obtaining documents—appellant entered her bedroom at night, covered her mouth (initially with a handkerchief, later with his hands, and ultimately not at all), and forced her to submit. She said her three siblings slept nearby but never woke. Physical examination by Dr. Rosario Fider on October 14, 1996 revealed superficially healed lacerations consistent with recent sexual intercourse. Appellant denied all charges, presenting alibi witnesses who testified t Case Digest (G.R. No. 147678-87) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- On October 30, 1996, ten separate informations for rape were filed against Efren Mateo y Garcia, each alleging carnal knowledge of his minor stepdaughter Imelda C. Mateo on ten different dates between October 7, 1995 and August 28, 1996 (Criminal Cases Nos. 9351–9360, RTC Tarlac, Branch 1).
- Appellant pleaded not guilty. Trial spanned three judges (1997–1999). The RTC, in a January 23, 2001 decision, convicted him on all counts and imposed reclusion perpetua for each, plus P50,000 actual and P50,000 moral damages per count.
- Testimonies and Evidence
- Victim’s Account
- Imelda (born September 11, 1980) lived with her mother Rosemarie Capulong and appellant, who adopted her surname. She alleged ten rapes occurring at night in their lone-bedroom house whenever her mother was supposedly away. She described force, gagging (handkerchief or hand), failed escape attempts, and presence of sleeping siblings.
- She initially detailed consistent modus operandi but later admitted contradictions on where siblings slept, whether her mouth was tied, and her mother’s whereabouts on specific dates. She never reported earlier due to threats.
- Medical Examination
- Dr. Rosario Fider (exam on October 14, 1996) found superficially healed lacerations on Imelda’s genitalia consistent with recent sexual intercourse or instrument insertion, possibly representing up to three incidents within two weeks.
- Appellant’s Defense and Alibi
- Appellant claimed continuous absence tending to ducklings (Oct 1995–Feb 1996), work at LA Construction (from May 8, 1996), and travel with his wife to Manila (July 1–3, 1996). He alleged malicious fabrication by Imelda to punish him for disciplining her.
- Witnesses (mother Rosemarie, neighbor Sharon Flores, friend Anselmo Botio, brother Marlon Mateo) corroborated his alibis, disputed Imelda’s account, and testified to Imelda’s conduct with a male companion.
Issues:
- Whether the prosecution proved beyond reasonable doubt that appellant committed ten counts of rape, despite inconsistencies in the victim’s testimony and credible alibi evidence.
- Whether, in cases imposing reclusion perpetua or higher, the Supreme Court should retain exclusive automatic review or introduce an intermediate review by the Court of Appeals.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)