Case Digest (G.R. No. 131516)
Facts:
People of the Philippines v. Ronnie Rullepa y Guinto, G.R. No. 131516, March 05, 2003, the Supreme Court En Banc, Carpio Morales, J., writing for the Court.The respondent in the criminal information was Ronnie Rullepa y Guinto (accused‑appellant); the private complainant and victim is identified in the record as AAA. On complaint of AAA, Ronnie was charged with rape before the Regional Trial Court (RTC) of Quezon City for acts alleged to have occurred on or about November 17, 1995, against AAA, then about three and a half years old. He was arraigned on January 15, 1996 and pleaded not guilty.
At trial the prosecution presented AAA, her mother, Dr. Ma. Cristina V. Preyra (Medico‑Legal Officer), and SPO4 Catherine Borda. AAA testified in graphic and spontaneous detail that Ronnie removed her panty and inserted his penis into her vagina, anus and mouth on two occasions; she described pain and crying. AAA told her mother on November 20, 1995; upon confrontation at home, the parents claimed Ronnie admitted having done it once on November 17 at 4:00 p.m., and he was detained after admitting the act at Camp Karingal. Dr. Preyra’s medico‑legal report (Nov. 21, 1995) found congested and abraded labia minora and an intact, elastic hymen; she concluded the subject was physically a virgin but that the abrasions could have been caused by friction with an erect penis.
The defense offered only Ronnie’s testimony denying the offense and alleging malice by the mother. The RTC, Branch 96, convicted Ronnie of rape and sentenced him to death, ordering P40,000 civil indemnity. Because a death sentence was imposed, the case reached the Supreme Court by automatic review. In his assignments of error Ronnie contended (I) the trial court erred in admitting his alleged admission, (...(Pro-only)
Issues:
- Did the trial court err in admitting the accused‑appellant’s alleged extrajudicial admission?
- Did the trial court err in treating the accused‑appellant’s silence during trial as an implied admission of guilt?
- Was the accused‑appellant’s guilt for the crime of rape proved beyond reasonable doubt?
- Was the imposition of the death penalty proper, i.e., was the victim’s age pr...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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