Case Digest (G.R. No. 135109-13)
Facts:
People of the Philippines v. Jose Pajo y Bagtong and Imelda Liquigan y Kasibayan, G.R. Nos. 135109-13, December 18, 2000, the Supreme Court En Banc, Per Curiam.The People prosecuted Jose Pajo y Bagtong (PAJO) and his live‑in partner Imelda Liquigan y Kasibayan (LIQUIGAN). Multiple informations were filed between 1996–1997 by AAA and her sister BBB (minors) accusing PAJO of three separate rapes and two counts of acts of lasciviousness, and accusing LIQUIGAN as accomplice in one rape (Criminal Cases Nos. 97‑233, 97‑664 to 97‑667). AAA was born April 13, 1983 (age 13 at time of the incidents). The accused pleaded not guilty and trial proceeded; the trial court later ordered consolidation of the related informations.
The Regional Trial Court (RTC) found both accused guilty on July 6, 1998. The RTC sentenced PAJO to death for the three rape convictions (Criminal Cases Nos. 97‑233, 97‑664, 97‑665) and to indeterminate prison terms for the two counts of acts of lasciviousness (Criminal Cases Nos. 97‑666, 97‑667); LIQUIGAN was found guilty as an accomplice in one rape and sentenced to reclusion temporal. The RTC also ordered PAJO to indemnify the victims and to pay costs.
PAJO and LIQUIGAN failed to perfect appeals in some of the consolidated cases by filing notices of appeal. Because the death penalty was imposed in three of the cases, those convictions were subject to automatic review by this Court; other cases where notices of appeal were not filed became final and executory and were dismissed by the Court for lack of appeal. The Supreme Court considered whether the convictions and the imposition of death under R.A. 7659 should be sustained on automatic review. Key trial evidence included the detailed testimonies of AAA and BBB describing incidents on August 18, 1996; September 18, 1996; November...(Pro-only)
Issues:
- Must the appeals in Criminal Cases Nos. 97‑666 and 97‑667 (PAJO) and Criminal Case No. 97‑664 (LIQUIGAN) be dismissed for failure to file notices of appeal?
- Did the prosecution prove beyond reasonable doubt that Jose Pajo committed three counts of qualified rape and that Imelda Liquigan was culpable as charged?
- May the death penalty be imposed under Article 335 of the Revised Penal Code as amended by R.A. 7659, given the proved attendant circums...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)