Case Summary (G.R. No. 121176)
Key Dates
- Case Docketed: November 27, 1995
- Court Decision: May 14, 1997
- Motion for Reconsideration: Filed May 29, 1997
- Medical Examination: Conducted on January 19, 1999
- Final Decision: July 8, 1999
Applicable Law
The decision in this case is governed by the 1987 Philippine Constitution, particularly regarding the fundamental right to due process.
Background of the Case
Marlon Parazo was convicted of rape and frustrated homicide, receiving the death penalty for the former and an indeterminate sentence for the latter. Following the imposition of these sentences, Parazo filed a Motion for Reconsideration, citing significant issues regarding his mental competence and the absence of a sign language expert during his initial trial.
Medical Evaluation and Findings
Subsequent evaluations found that Marlon Parazo suffers from profound deafness and mild mental retardation, with an estimated IQ of 60 and a mental age equivalent to 7 years and 9 months. The medical examinations revealed significant limitations in his cognitive and communicative abilities, with the evaluations performed by qualified physicians indicating that Parazo cannot fully comprehend spoken or written language. This lack of communication severely impaired his ability to participate in his defense.
Procedural Deficiencies
The initial trial was conducted without the assistance of a qualified sign language interpreter, which is critical for a defendant who is deaf and mute. The absence of effective means of communication not only impeded Parazo’s understanding of the charges against him but also deprived him of the opportunity to present his side of the story adequately—a violation of his right to a fair trial under the Constitution.
Relevant Case Law
The decision drew upon precedents, notably the case of People v. Crisologo, which emphasized that the absence of a qualified interpreter for a deaf-mute defendant prevents a just and fair trial. This absence results in a violation of the due process rights which are fundamental to legal proceedings.
Conclusion and Order
Given the findings of the medical evaluations, the procedural inadequacies, and the legal precedents cited, the court concluded that the accused's previous trial proces
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Case Overview
- The case is an automatic review of Criminal Case Nos. 6167 and 6168, concerning the accused-appellant Marlon Parazo y Francisco, who faced charges of rape and frustrated homicide.
- The case was brought before the Supreme Court on November 27, 1995, following a decision by Branch 27 of the Regional Trial Court in Cabanatuan City that imposed the death penalty on the accused.
- On May 14, 1997, the Supreme Court affirmed the conviction for rape while modifying the sentence for frustrated homicide.
Background of the Case
- The Regional Trial Court's joint decision dated March 24, 1995, was appealed, resulting in the Supreme Court's ruling.
- In the decision, the Court upheld the conviction for rape under Section 11 of Republic Act No. 7659, citing the aggravating circumstance of dwelling.
- The court imposed the death penalty for the rape conviction while sentencing for frustrated homicide to an indeterminate penalty of six years of prision correccional to twelve years of prision mayor.
Motion for Reconsideration
- Following the decision, on May 29, 1997, the appellant filed a Motion for Reconsideration citing the absence of a sign language expert during the trial, which he argued compromised his defense.
- On February 10, 1998, the Supreme C