Title
People vs. Yu
Case
G.R. No. L-13780
Decision Date
Jan 28, 1961
The Supreme Court ruled on the evidentiary standards for criminal liability in People v. Yu, emphasizing the necessity of establishing guilt beyond reasonable doubt.
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Case Digest (G.R. No. L-13780)

Facts:

  • Case: People vs. Yu (G.R. No. L-13780)
  • Date Decided: January 28, 1961
  • Plaintiff-Appellee: The People of the Philippines, represented by the Solicitor General
  • Defendant-Appellant: Antonio Yu, alias Sostenes Yongco, represented by Enrique M. Fernando
  • Incident Date: November 14, 1957
  • Location: City of Davao, Philippines
  • Charges: Rape with murder under Article 335 in relation to Article 248 of the Revised Penal Code
  • Details:
    • The accused raped 6-year-old Delia Abule using violence and intimidation.
    • He subsequently killed her by strangulation to silence her cries.
    • Aggravating circumstances: evident premeditation and employment of craft.
    • Mitigating circumstances: plea of guilty and lack of intent to commit so grave a wrong.
  • Lower Court Ruling: Found guilty beyond reasonable doubt, sentenced to death, with an indemnity of P6,000.00 to the heirs of the deceased.
  • Automatic Review: Case brought to the Supreme Court for automatic review.

Issue:

  • (Unlock)

Ruling:

  1. Jurisdiction: Yes, the lower court had jurisdiction to try the offenses.
  2. Complex Crime: No, the lower court did not err in finding that the defendant-appellant committed the complex crime of rape with murder.
  3. Death...(Unlock)

Ratio:

  1. Jurisdiction:

    • The Supreme Court held that the trial court had jurisdiction despite the complaint not being signed by the victim's parents or guardian.
    • The crime was complex and involved public interest, allowing the provincial fiscal to sign the complaint.
    • References: Pueblo vs. Orcullo and Republic Act No. 2632, amending Article 335 of the Revised Penal Code.
  2. Complex Crime:

    • The Court confirmed that the appellant committed the complex crime of rape with homicide.
    • The crimes were committed simultaneously, making it a complex crime.
    • The killing was qualified as murder due to the use of superior strength.
    • The appellant’s testimony corroborated the simultaneous commission, with strangulation during the rape.
  3. Death Sentence:

    • The Supreme Court upheld the death sentence.
    • The plea of guilty covered the crime and its circumstances, establishing aggravating circumstances.
    • The mitigating circumstance of lack of intent to commit so grave a wrong was not accepted.
    • The a...continue reading

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