Case Digest (G.R. No. 54135)
Facts:
People of the Philippines v. Policarpio Rafanan, Jr., G.R. No. 54135, November 21, 1991, Supreme Court First Division, Feliciano, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the defendant-appellant is Policarpio Rafanan, Jr.The trial court (then Court of First Instance of Pangasinan) summarized the prosecution evidence: in February–March 1976 the 14‑year‑old complainant, Estelita Ronaya, was hired as a househelper by the accused’s mother and lived in the accused’s household. On the evening of March 16, 1976, while helping to close the family store, Estelita was allegedly pulled inside the store by the accused, threatened with a bolo about 1½ feet long, forced onto a bamboo bed, had her pants and panty removed, and was sexually assaulted despite struggling and crying. The accused allegedly cautioned her not to report the incident and threatened to kill her if she did; the complainant left the house only the next day, March 17–18, and her mother later reported the matter to the police. The bolo was reportedly recovered and presented in evidence.
At arraignment the appellant pleaded not guilty. After trial the Court of First Instance convicted Rafanan of rape and sentenced him to reclusion perpetua, ordered him to indemnify the complainant P10,000.00 moral damages, and to pay costs. Rafanan appealed, assigning errors that (1) the conviction rested solely on the testimony of the complainant and her mother; (2) the trial court erred in considering hearsay Exhibits B and C; (3) the trial court erred in not believing defense expert testimony as to his mental condition; and (4) he was insane at the time of the offense.
At the urging of defense counsel during trial, the trial court suspended the proceedings and ordered Rafanan confined for psychiatric observation and treatment at the National Mental Hospital, Mandaluyong. He was admitted December 29, 1976 and discharged June 26, 1978. The hospital produced four clinical reports (27 Jan. 1977; 21 June 1977; 5 Oct. 1977; 26 June 1978) signed by Dr. Simplicio N. Masikip and Dr. Arturo E. Nerit. Early reports described him as psychotic/insane and unfit to stand trial (schizophrenic features, disorientation, hallucinations); later reports showed clinical improvement and concluded he was in a mental condition to stand trial by June 1978.
Upon resumption of trial, the defense presented Dr. Nerit and Dr. Raquel Jovellano as expert witnesses to support a plea of insanity. The pro...(Subscriber-Only)
Issues:
- Did the trial court err in convicting appellant based essentially on the testimony of the complainant and her mother?
- Did the trial court err in considering the prosecution’s Exhibits B and C which appellant contended were hearsay?
- Did the trial court err in discounting the defense expert testimony about appellant’s mental condition?
- Was appellant legally insane at the time of the rape so as to be exempt from criminal liability und...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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