G.R. No. 109149 - People vs. Santocildes, Jr. y Siga-an

On February 17, 1992, the appellant, Leoncio Santocildes, Jr., was charged with the crime of rape committed on December 28, 1991, in Barangay San Luis, San Joaquin, Iloilo.
The rape involved the victim, a girl less than nine years old, and the case was prosecuted by the People of the Philippines.

Upon arraignment, the appellant entered a plea of not guilty.
The case proceeded to trial where the presentation of evidence and witness testimonies became pivotal.

A witness identified as German Toriales.
His own testimony, wherein he denied the commission of rape, asserting he merely attempted to stop a quarrel between the girl and her playmate.

On October 29, 1992, the Regional Trial Court of Iloilo City, Branch 33, rendered its decision finding the appellant guilty as charged.
The sentence imposed was reclusion perpetua, together with accessory penalties. Additionally, the appellant was ordered to pay P50,000.00 to the complainant along with costs.

During trial, the appellant was represented by an individual named Gualberto C. Ompong who conducted direct examination and cross-examinations.
After filing his Notice of Appeal, the appellant secured new counsel, Atty. Igmedio S. Prado, Jr., who discovered and verified that Gualberto C. Ompong was not a member of the Philippine Bar.
The appellant argued that being represented by a non-lawyer deprived him of his right to due process by not affording him proper legal representation.
The Office of the Solicitor General maintained that despite the unauthorized status of the trial counsel, the defense had been presented in a professional manner; however, the issue went deeper than mere skillfulness.

The case raised significant issues regarding the right to counsel as enshrined in the 1987 Constitution and relevant rules of criminal procedure.
Precedents such as Delgado v. Court of Appeals and People v. Bermas were cited to underscore the necessity of representation by a member of the bar to safeguard the due process rights of the accused.
The unauthorized practice of law and its consequences were highlighted with judicial references including Beltran, Jr. v. Abad and the Rules of Court provisions regarding indirect contempt for unauthorized practice.

Whether the trial court’s conviction of the appellant for rape should be set aside due to issues with conflicting testimonies presented by the private complainant and her witnesses.

The appellant argued that the inconsistencies in the testimonies compromised the integrity of the evidence.
This issue raised the broader context of evidentiary reliability in criminal proceedings.

Whether the appellant's right to due process was violated because he was represented during trial by an individual who was not a member of the Philippine Bar.

The appellant contended that effective legal representation is a constitutional right, and representation by an unauthorized person undermines this right.
The case pivots on whether the procedural rules and constitutional guarantees on the right to counsel were adequately met in his trial proceedings.