Case Digest (G.R. No. 130334)
Facts:
The People of the Philippines v. Reynaldo Ponado, G.R. No. 130334, July 28, 1999, Supreme Court En Banc, Vitug, J., writing for the Court.The respondent-appellant, Reynaldo Ponado, was charged in three separate informations with three counts of rape under Article 335 of the Revised Penal Code as amended by Republic Act No. 7659. Each information alleged that Ponado, “with grave abuse of his parental authority,” had carnal knowledge of his “stepdaughter” Merinor (Marilou) Bombales on dates in October 1995 and September–October 1996. At arraignment Ponado pleaded not guilty; the prosecution and defense agreed to a joint trial before the Regional Trial Court (RTC), Branch 13, Ligao, Albay.
The factual background: Merinor is the daughter of Marcelino Bombales and Librada Rectin. After separating from Marcelino, Librada lived with Ponado in a common-law relationship and brought her four children. Merinor testified that Ponado—whom she regarded as a stepfather—sexually assaulted her on three occasions (8 October 1995, 8 September 1996, and 7 October 1996), describing forced intercourse, covering her mouth, tying her with rope on the last occasion, and repeated kissing and penetration. She reported the assaults to classmates, teachers, barangay officials and the police the day after the last incident.
A medico-legal exam by Dr. Lea Remonte (8 October 1996) showed a superficial hymenal laceration at the 1 o’clock position, easy admission of two fingers, and a milk-like whitish discharge; no spermatozoa or external bruises were noted. Ponado denied the charges, claiming alibis and suggesting Merinor’s brother Danilo might be responsible. His father and son testified for the defense that Merinor had flirtatious behavior and may have had an illicit relationship with Danilo.
The RTC found Merinor’s testimony credible, convicted Ponado beyond reasonable doubt of three counts of rape, and sentenced him to death on each count while ordering indemnity of P150,000. Because the death penalty had been imposed under R.A. 7659, the case was automatically elevated to the Supreme Court for review. Ponado raised two assignments of error: insufficiency of evidence to support convi...(Pro-only)
Issues:
- Was the accused proven guilty of rape beyond reasonable doubt?
- Does the defective allegation in the informations (stating the victim was the accused’s “stepdaughter” when the accused was only a common‑law partner) preclude imposition of the death penalty under Section 11 of R.A. No. 7659?
- Does the death-penalty provision of R.A. No. 7659 violate the Equal Protect...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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