Case Summary (G.R. No. 110776)
Parties and Procedural Posture
Prosecution: The People of the Philippines (appellee). Defense: Efren Mateo (appellant). Ten separate informations for rape (Criminal Cases Nos. 9351–9360, RTC of Tarlac) were filed on 30 October 1996, each alleging rape on different dates. Appellant pleaded not guilty; trial followed and the trial court rendered judgment of conviction; the matter reached the Supreme Court on automatic review because reclusion perpetua was imposed.
Charges and Informations
Ten informations, identical in form except for the dates, charged appellant with rape committed on ten different alleged dates (07 Oct 1995; 14 Dec 1995; 05 Jan 1996; 12 Jan 1996; 29 Feb 1996; 08 May 1996; 02 Jul 1996; 18 Jul 1996; 16 Aug 1996; 28 Aug 1996). Each information alleged appellant, the guardian of the complaining witness, willfully, unlawfully and by force and intimidation had carnal knowledge of Imelda in their house in Buenavista, Tarlac.
Prosecution Fact Narrative and Victim Testimony
Imelda testified that the ten incidents followed a consistent pattern: nocturnal intrusions into her bedroom or removal to the sala, physical overpowering, covering of her mouth to prevent shouting (initially described as a tied handkerchief in some instances, later as the accused’s hand, and eventually she repudiated the covering allegation entirely), and that each assault occurred when her mother was allegedly absent. Imelda recounted threats by appellant to kill her and her mother if she disclosed the crimes. She also testified she tried some protective measures (asking siblings to sleep with her, acquiring a knife which she failed to use when appellant sat atop it). She explained why she did not report earlier by reference to threats and intimidation. Imelda’s account, however, contained multiple variations and inconsistencies on key points (who slept where on certain nights, whether her mouth was covered and by what, precise whereabouts of her mother on alleged dates, and other details).
Medical Evidence
Dr. Rosario Fider examined Imelda on 14 October 1996 and reported superficially healed lacerations at the 3:00, 6:00 and 9:00 positions of the genital organ, which could have been caused by insertion of an instrument or sexual intercourse. Dr. Fider opined these lacerations suggested possibly one or two, and at most three, incidents of rape not earlier than two weeks before the examination.
Defense Narrative and Alibi Evidence
Appellant denied all allegations and presented alibi and work-related explanations. He testified that from October 1995 until about February 1996 he cared for newly hatched ducks in a field (spending days and nights away from home, returning only occasionally). He claimed work at LA Construction required overnight work starting 08 May 1996 and nightshift assignments from 15 July to September 1996. Appellant presented witnesses who placed him away from home on critical dates, specifically friends who said they were with him at a fiesta on 28 August 1996. He also offered a motive to fabricate: he disciplined Imelda for alleged sexual activity with a man (Pikong Navarro) observed by his son, and argues that Imelda thus bore animus and could have falsely accused him.
Testimony of Mother and Other Witnesses
Rosemarie Capulong testified in defense of appellant, contradicting Imelda’s claims regarding her alleged absences. She maintained she was generally at home, denied attending several seminars on dates Imelda claimed, and placed initial Manila travel relating to overseas employment documentation at February–June 1996. Rosemarie corroborated portions of appellant’s alibi concerning his whereabouts and activities. Sharon Flores testified she observed Imelda with Pikong Navarro in a compromising situation on 05 August 1996. Marlon Mateo and friends corroborated aspects of appellant’s alibi and the incident of discovery of Imelda and Navarro.
Trial Court Verdict
The trial court (decision dated 23 January 2001) found appellant guilty beyond reasonable doubt of ten counts of rape and sentenced him to reclusion perpetua for each count, and ordered indemnity of P50,000 actual damages and P50,000 moral damages per count.
Credibility Issues and Conflicts in Evidence
The Solicitor General and the Supreme Court majority highlighted substantial inconsistencies and improbabilities in Imelda’s testimony: contradictory accounts of sleeping arrangements within the single-room house (claims varied as to who slept where on the nights of alleged attacks); multiple changing statements about whether the victim’s mouth was tied, gagged with a handkerchief, or not covered at all; inconsistent explanations about the mother’s whereabouts on key dates (seminar attendance, work, travel); and other discrepancies (e.g., representing a weekday as a school day though 7 October 1995 was a Saturday). The Court noted the absence of expected behavioral changes by the victim (continued routine activities, no escape attempts), and medical findings consistent with at most a few recent incidents rather than ten distinct events.
Legal Standard on Victim Testimony and Credibility
The Court reiterated the established rule that conviction for rape can rest solely on the uncorroborated testimony of the victim if that testimony is credible, convincing and straightforward. The Court emphasized that reliance on such testimony is justified because the victim is often the sole witness and cultural factors may deter fabrication, but stressed that the testimony must be free of serious doubt. Where testimony contains material contradictions or improbabilities, the Court cautioned against accepting it as proof beyond reasonable doubt.
Procedural Concerns: Multiple Trial Judges and Appellate Review
The Supreme Court observed that the trial proceeded before three different judges at various stages, which, while not voiding proceedings, deprived any single presiding judge of continuous live observation of witness demeanor throughout trial—an important factor where credibility is central. More broadly, the Court discussed the constitutional basis for automatic Supreme Court review (1987 Constitution, Article VIII, Section 5) of cases where reclusion perpetua, life imprisonment or death is imposed and the attendant heavy workload and statistical results of automatic review (high rates of modification, reduction, remand, and acquittal). The Court noted an absence of unanimity amon
...continue readingCase Syllabus (G.R. No. 110776)
Procedural Posture and Case Title
- The case is styled "The People of the Philippines, Appellee, vs. Efren Mateo y Garcia, Appellant."
- Ten informations, one for each count of rape, were filed against appellant on 30 October 1996; they were later docketed as Criminal Cases No. 9351 to No. 9360, inclusive, in the Regional Trial Court of Tarlac.
- Each information, except for the variance in dates, uniformly charged appellant (described as "the guardian of the complaining witness") with rape and recited substantially the same allegation (including a quoted sample information describing the offense on or about January 12, 1996).
- Appellant pleaded not guilty to all ten charges and was tried; at the conclusion of the trial, the trial court rendered a decision dated 23 January 2001 finding appellant guilty beyond reasonable doubt of ten counts of rape.
- Sentencing by the trial court: reclusion perpetua for each count; indemnity of P50,000.00 as actual damages and P50,000.00 as moral damages for each count.
- The Solicitor General filed a brief urging acquittal; the Supreme Court reviewed the case and, after discussing factual and procedural issues and broader rule-making concerns, remanded the case to the Court of Appeals for appropriate action and disposition.
- The Supreme Court issued the remand order en banc; the opinion notes concurrence by Chief Justice Davide, Jr. and Justices Puno, Panganiban, Quisumbing, Ynares-Santiago, Sandoval-Gutierrez, Carpio, Austria-Martinez, Corona, Carpio-Morales, Callejo, Sr., Azcuna, and Tinga.
Facts as Alleged by the Prosecution (Summary of Complainant's Account)
- Ten rape incidents were alleged to have occurred on separate dates: 07 October 1995, 14 December 1995, 05 January 1996, 12 January 1996, 29 February 1996, 08 May 1996, 02 July 1996, 18 July 1996, 16 August 1996 and 28 August 1996.
- The private complainant is Imelda C. Mateo, born 11 September 1980, daughter of Dan Icban and Rosemarie Capulong. She adopted appellant's surname when she began schooling because Rosemarie and appellant lived together as common-law partners.
- Imelda testified that the rape incidents occurred inside the house in Buenavista, Tarlac, during the night, and that appellant was her guardian and committed the acts against her will by force and intimidation.
- Imelda stated that on every occasion her mother, Rosemarie, was absent from the house; she gave specific reasons and destinations for Rosemarie's absence tied to each alleged incident (seminars, travel to Manila, job-related matters, etc.).
- Typical pattern asserted by Imelda: appellant entered her room at night, gagged her (initially testified as with a handkerchief; later varied to hands or no gag), overcame her physical resistance (she would kick but he was too strong), and in some accounts moved her to the sala where the abuse continued; her three siblings were allegedly present and sleeping during several incidents and did not wake despite her struggles.
- Imelda alleged threats by appellant that he would kill her and her mother if she disclosed the incidents; this was offered to explain delay in reporting.
- Imelda recounted at least one attempt to take protective measures: she armed herself with a knife on the night of the fourth alleged rape but was unable to retrieve it when appellant entered and sat atop the bed.
Medical and Forensic Evidence
- Dr. Rosario Fider examined Imelda on 14 October 1996.
- Dr. Fider observed superficially healed lacerations at the 3:00, 6:00 and 9:00 positions on Imelda's private organ. She opined that such lacerations could have been caused by the insertion of an instrument or by sexual intercourse.
- Dr. Fider testified that the lacerations pointed to possibly one or two, and at most three, incidents of rape, and that these had happened not earlier than two weeks before the date of the physical examination.
Defense Evidence and Alibi (Appellant's Account)
- Appellant denied all charges and offered alibi and work-related explanations for his whereabouts during many of the alleged incidents.
- Appellant claimed that beginning 07 October 1995 he was in Barangay Talaga, Capas, to pick up newly hatched ducklings (approximately one thousand) and that the care of these fowls required his constant attendance both day and night for about two weeks and thereafter tending the animals in an open field about 1.5 kilometers away; he said he tended the ducks from 20 October 1995 until sometime in February 1996 and could go home only infrequently.
- For 14 December 1995 (second alleged rape) appellant admitted briefly returning from tending ducks to go caroling with his wife and daughter and friends, but claimed he quickly returned to the birds located some 500 meters from home.
- Appellant testified that he sold the ducks prior to 08 May 1996 and that on 08 May 1996 he was accepted and reported for work at LA Construction of Hacienda Luisita, Tarlac, working from 7:00 a.m. and through to the following day to finish a rush job, which accounted for his non-presence at home that night.
- Appellant recounted that on 01 July 1996 he accompanied his wife Rosemarie to Manila for her scheduled departure to Jeddah; they stayed in Caloocan when the flight was postponed and appellant returned to Tarlac on 03 July. From 15 July to September 1996 he was given the nightshift at LA Construction, explaining his nighttime whereabouts.
- For the 28 August 1996 alleged incident appellant asserted an alibi: at 6:00 p.m. friends Boy Botio, Boy Pineda, Marvin Dalangin and Nelson Castro picked him up to attend the fiesta at Barangay Murcia, Concepcion, Tarlac; they arrived at about 7:00 p.m., had dinner and a drinking spree, and spent the night there.
- Appellant alleged motive for fabrication: that Imelda was a vengeful stepdaughter who acted out after appellant disciplined her on or about 11 October 1996 (after learning from his son Marlon that Imelda had been seen engaging in sexual intercourse with Pikong Navarro), including having hit her twice with a piece of bamboo and restricting her movements thereafter.
Testimony of Mother and Other Defense Witnesses (Corroboration of Alibi and Contradictions to Prosecution)
- Rosemarie Capulong (Imelda’s mother and appellant’s common-law wife) testified in defense of appellant and contradicted critical aspects of Imelda's testimony:
- Rosemarie asserted she had not spent nights away from their house prior to departing for Jeddah and denied many of the absences Imelda attributed to her.
- She said she was a day-care teacher from June 1990 until June 1996, denied attending seminars except regular half-day meetings held monthly, and claimed the last seminar she attended was in June 1990.
- Rosemarie maintained she was at home on dates Imelda alleged she was absent (including 07 October 1995 and 29 February 1996) and that she began obtaining documents for overseas employment on 12 February 1996, not earlier.
- Rosemarie corroborated appellant's account of his tending the ducks from October 1995 and the caroling in December; she admitted being away from home for a general assembly in Zambales on 08 May 1996 and that appellant worked overtime that early morning.
- Rosemarie testified she went to Manila for the first time on 13 February 1996 to attend to employment papers and made subsequent day trips in Ju