Case Digest (G.R. No. 92586)
Facts:
People of the Philippines v. Edgardo Puedan y Lalongisip, G.R. No. 92586, April 26, 1991, Supreme Court First Division, Grino‑Aquino, J., writing for the Court.The criminal case arose from a complaint filed on May 31, 1988 by Celestina Simbahan with the Manila City Fiscal’s Office (later refiled in the Regional Trial Court of Manila, Branch V, as Criminal Case No. 88-63617) charging her granddaughter, four‑year‑old Snaier Edwards y Risaba, had been raped by her uncle, Edgardo Puedan y Lalongisip. The complaint alleged that on or about May 15, 1988, in Manila, Puedan locked the child in a room, removed her panty and, by force and intimidation, inserted his index finger in her vagina (the information alleged carnal knowledge). On July 26, 1988 the accused pleaded not guilty.
At trial the prosecution presented Snaier’s testimony identifying appellant as the assailant and medical evidence from Lt. Col. Desiderio Moraleda, Chief Medico‑Legal Officer of Camp Crame, who reported hymenal laceration (shallow healing laceration at 4:00 o’clock), congestion of the vulvar mucosa, and concluded the subject was “in non‑virgin state physically”; smears were negative for spermatozoa. The victim also testified that appellant removed his pants and inserted his penis in her private parts and that he burned her arms and legs with a lighted cigarette to stop her crying. Defense testimony denied the charge and suggested other male relatives who lived upstairs could have committed the act; defense also offered a letter from Snaier’s mother, Socorro Risaba, expressing disbelief that appellant would commit the act.
The trial court, having observed the witnesses, found the victim credible and convicted appellant of rape on September 25, 1989, sentencing him to reclusion perpetua and ordering P10,000 damages. Appellant filed a notice of appeal on October 2, 1989. The case reached the Supreme Court on appea...(Subscriber-Only)
Issues:
- Was the information fatally defective for failing to state the precise time and date of the alleged rape, such that conviction could not be sustained?
- Was the victim’s testimony so inherently improbable or coached that the trial court erred in crediting it?
- Did the trial court err in failing to give exculpatory weight to the defense evidence so a...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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