Case Digest (G.R. No. 150224)
Facts:
People of the Philippines v. Joel Yatar alias Kawit, G.R. No. 150224, May 19, 2004, the Supreme Court En Banc, Per Curiam. The appellee is the People of the Philippines; the appellant is Joel Yatar alias Kawit.On June 30, 1998, seventeen-year-old Kathylyn D. Uba was found dead, naked and with multiple stab wounds and her intestines protruding, on the second floor of her grandmother Isabel Dawang’s house in Liwan West, Rizal, Kalinga. Witnesses placed appellant—who had been living in the same house with his wife and the victim prior to separating from his wife—in or near the house earlier that day. Witnesses testified the victim had earlier handed appellant a letter from his estranged wife; other testimony recounted prior attempts by appellant to assault the victim and threats made by him against the family after his wife left him. A bloody dirty white shirt was found within 50 meters of the house; the victim’s stained garments and sandals were scattered around her body. Police found semen in the victim’s vaginal canal.
Appellant was arrested, attempted to flee custody on July 3, 1998 but was recaptured, arraigned July 21, 1998 and pleaded not guilty. Blood was taken from appellant in open court on March 30, 2000. The U.P. National Science Research Institute (NSRI) performed PCR/STR DNA analysis; the DNA profile from the semen matched appellant’s blood sample. After trial, the Regional Trial Court (RTC), Bulanao, Tabuk, Kalinga, Branch 25 (Decision penned by Judge Milnar T. Lammawin, August 27, 2001) convicted appellant of the special complex crime of Rape with Homicide under Articles 266-A and 266-B, as amended by R.A. 8353, and sentenced him to Death; it also ordered payment of various damages totaling P511,410.00 and costs.
Appellant sought relief by raising two principal assignments of error in his brief: (1) that the trial court gave undue weight to doubtful prosecution evidence and improperly assessed credibility; and (2) that the trial court erred in not acquitting him on the basis of reasonable doubt. The case came to the Supreme Court on automatic review pursuant to Article 47 of the Revised Penal Code (as amended), and the Court heard and resolved issues including the admissibility and probative value of DNA evidence, alle...(Pro-only)
Issues:
- Did the trial court properly assess the credibility and weight of the prosecution’s evidence?
- Were appellant’s constitutional rights against self-incrimination violated by compelled blood sampling and subsequent DNA testing?
- Do the DNA tests and their admission violate the prohibition against ex post facto laws?
- Did the prosecution prove beyond reasonable doubt the elements of the special complex crime of rape with homicide so as to ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)