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:
- Jurisdiction: Yes, the lower court had jurisdiction to try the offenses.
- Complex Crime: No, the lower court did not err in finding that the defendant-appellant committed the complex crime of rape with murder.
- Death...(Unlock)
Ratio:
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.
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.
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
Case Digest (G.R. No. L-13780)
Facts:
The case involves Antonio Yu, also known as Sostenes Yongco, who was accused of the complex crime of Rape with Murder. The incident occurred on or about November 14, 1957, in the City of Davao, Philippines. The amended information filed against him stated that he forcibly had carnal knowledge of Delia Abule, a six-year-old girl, against her will. To silence her cries during the act, he allegedly attacked, assaulted, and strangled her, resulting in her death. The prosecution highlighted two aggravating circumstances: the employment of craft and evident premeditation.
During the trial, with the assistance of a court-appointed counsel, Yu pleaded guilty to the charges but reserved the right to present evidence for the mitigating circumstance of "lack of intent to commit so grave a crime." The Court of First Instance (CFI) of Davao found him guilty beyond reasonable doubt of the complex crime of Rape with Murder, considering both aggravating and mitigating circumstances. The court imposed the death penalty, stating that the crime of murder was more serious than rape, and thus the maximum penalty for murder, as prescribed by Article 248 of the Revised Penal Code, was applicable. The case was subsequently brought before the Supreme Court for automatic review.
Issue:
- Did the lower court have jurisdiction to try the offenses despite the complaint not ...