Case Summary (G.R. No. 147678-87)
Petitioner and Respondent
• Appellee: The People of the Philippines
• Appellant: Efren Mateo y Garcia
Key Dates
• October 7, 1995–August 28, 1996: Ten alleged rape incidents
• January 12, 1996: Date variance sample in informations
• July 23, 2001: Trial court decision convicting appellant
• July 7, 2004: Supreme Court decision remanding case
Applicable Law
• 1987 Constitution, Article VIII, Section 5(2) (automatic review of reclusion perpetua cases) and Section 5(5) (rule-making power)
• Revised Penal Code, Article 47 (as amended by RA 7659)
• Rules of Court, Rule 122 (Sections 3, 10), Rule 124 (Section 13), Rule 125 (Section 3)
Facts of the Case
Imelda Mateo testified that her stepfather raped her ten times between October 1995 and August 1996, always at night inside their house while her mother was allegedly away on various errands or seminars. She described a uniform modus operandi: covering her mouth (initially by handkerchief, later by hand), moving her to the sala, and subduing her physical resistance. She claimed fear of disclosure due to death threats. Physical examination months later revealed superficial healed lacerations consistent with one to three sexual assaults within the preceding two weeks. Appellant denied all allegations, presented continuous alibi evidence—tending ducklings in Capas, working overnight at LA Construction, attending a fiesta in Concepcion—and challenged the victim’s credibility as motivated by vengeance. Mother Rosemarie Capulong and other family members testified that the household’s lone bedroom was occupied by the parents and that children slept in the sala; they denied many of the victim’s claims regarding their absence and travel dates.
Procedural History
Ten separate informations for rape were docketed as Criminal Cases No. 9351–9360 before the Regional Trial Court of Tarlac. Appellant pleaded not guilty to all counts. The trial spanned multiple presiding judges between July 1997 and February 1999, with the closing hearings in May 1999. On January 23, 2001, the court convicted appellant on all ten counts of rape, imposing reclusion perpetua per count and awarding P50,000 actual plus P50,000 moral damages each. Under existing law, the conviction was subject to automatic review by the Supreme Court.
Trial Court Findings and Legal Standards
The trial court relied on the victim’s testimony, in line with jurisprudence recognizing that rape convictions may rest on uncorroborated yet credible victim‐witness accounts. It found Imelda’s narrative sufficiently consistent and straightforward to satisfy proof beyond reasonable doubt. The court rejected alibi testimony as less persuasive in face of the victim’s sustained allegations and medical findings.
Issues on Appeal
• Credibility of the victim’s testimony in light of material inconsistencies regarding sleeping arrangements, gagging methods, and mother’s presence
• Sufficiency of alibi and corroborative evidence provided by appellant and family witnesses
• Impact of multiple presiding judges on assessment of witness demeanor
• Proper procedural route for appellate review in reclusion perpetua cases
Supreme Court’s Analysis on Credibility
The Court noted irreconcilable discrepancies in the victim’s account: shifting statements on who shared the lone bedroom, whether her mouth was covered by hand or handkerchief, and contradictory claims about her mother’s whereabouts and activities. The lack of behavioral changes or attempts to seek help further undermined the victim’s narrative. Conversely, appellant’s alibi testimony—supported by multiple witnesses—demonstrated his presence elsewhere during alleged rape dates. The change of judges throughout trial impeded a single fact‐finder’s full observation of witness demeanor, affect
...continue readingCase Syllabus (G.R. No. 147678-87)
Parties and Procedural Posture
- Appellee: The People of the Philippines
- Appellant: Efren Mateo y Garcia
- Docketed as Criminal Cases Nos. 9351–9360 before the Regional Trial Court of Tarlac
- Charged with ten counts of rape, each alleging distinct dates between October 1995 and August 1996
- Trial court convicted appellant of all ten counts of rape and imposed reclusion perpetua per count, plus damages
- Case automatically elevated to the Supreme Court for review under constitutional and Rules of Court provisions
Factual Background
- Victim, Imelda C. Mateo, born 11 September 1980, lived with her mother (Rosemarie Capulong) and appellant in Buenavista, Tarlac
- Appellant acted as Imelda’s guardian and adopted parent role
- Ten allegations of rape spanned from 07 October 1995 to 28 August 1996, each occurring at night inside the family home
- Victim claimed appellant used force and intimidation, covered her mouth, and prevented outcry during each assault
- Imelda’s three siblings slept in the same house and, at times, in the same room, yet did not awaken
Trial Court Findings
- Victim’s uncorroborated testimony deemed credible enough to establish guilt beyond reasonable doubt
- Medical evidence indicated healed lacerations consistent with one to three past sexual assaults
- Trial court ruled that consistent pattern of abuse, victim’s fear of threats, and injuries met the elements of rape
- Sentence: Reclusion perpetua for each count; P50,000 actual damages and P50,000 moral damages per count
Victim’s Testimony and Internal Discrepancies
- Imelda described ten near-identical incidents: nighttime entry, restraint, gagging, forced intercourse
- Multiple shifts in recounting how appellant covered her mouth (handkerchief, hand, or no gag)
- Contradictory statements on bedroom occupancy: whether siblings and stepfather slept in the lone room or sala
- Inconsistent account of mother’s whereabouts—seminars, work trips, residence in Bamban or Manila
- Changes under cross-examination caused serious doubt on the reliability of her narrative
Prosecution’s Medical Evidence
- Dr. Rosario Fider examined Imelda on 14 October 1996
- Found superficially healed lacer