Case Digest (G.R. No. 102773-77)
Facts:
People of the Philippines v. Godofredo Sayat, G.R. No. 102773-77. June 08, 1993, the Supreme Court Second Division, Regalado, J., writing for the Court. The prosecution (plaintiff-appellee) charged Godofredo Sayat (accused-appellant) with five counts of rape in five separate complaints filed in the Regional Trial Court of Pasig, Branch 156 (Crim. Cases Nos. 85574–85578), each complaint alleging carnal knowledge of his eight-year-old half-sister Marites (Maritess) P. Sayat on five successive dates from August 28 to September 1, 1990. The complaints were substantially identical except for dates of the alleged offenses.Appellant pleaded not guilty. After a consolidated trial, the trial court rendered judgment on October 15, 1991, finding appellant guilty beyond reasonable doubt of five counts of rape under Article 335(3) of the Revised Penal Code, with the aggravating circumstance of relationship, and sentenced him to five terms of reclusion perpetua, ordered indemnity of P30,000, and credited preventive imprisonment consistent with the Three-Fold Rule. Appellant appealed, assigning as lone error that the trial court erred in finding him guilty beyond reasonable doubt.
The evidence at trial included the direct testimony of the child complainant describing five separate sexual assaults by appellant, the testimony of a relative (Maribel Halino) who observed the child’s fearful condition, and the medico-legal examination by Dr. Emmanuel L. Aranas that found a congested hymen with a healed laceration consistent with prior penetration. Appellant testified to an alibi that he stayed with his common-law wife in Sampaloc for two weeks and denied being at the Pasig house during the incidents. A birth certificate identified as Exhibit “F” was marked but, the record shows, was not formally offered at trial.
The trial court credited the complainant’s testimony and convicted. On appeal to this Court (by appellant’s direct appellate action as recounted in the ...(Pro-only)
Issues:
- Was the conviction for five counts of rape supported by proof beyond reasonable doubt?
- Was the aggravating circumstance of relationship proven despite the birth certificate not having been formally offered?
- Was the increase of moral d...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)