View full case

PEOPLE v. RESTITUTO MANHUYOD

FACTS:

The case involves a father who allegedly raped his 17-year-old daughter after the effectivity of R.A. No. 7659. The trial court imposed the death penalty on the accused based on the aggravating circumstance of relationship under Article 15 of the Revised Penal Code. The Supreme Court finds that the conviction was based on hearsay evidence and a miscomprehension of the rule on statements forming part of the res gestae, violating the accused's right to the presumption of innocence.

The facts include the filing of a rape complaint by the accused's wife and mother of the victim. The victim was examined by a Medico-Legal Officer, whose findings showed evidence of old healed lacerations on her hymen. Sworn statements were given by the wife and the victim, and a letter recommending the prosecution of the accused was sent to the Provincial Prosecutor's Office. An information charging the accused with rape was filed, and the accused pleaded not guilty.

The prosecution filed a motion to dismiss based on a joint affidavit of desistance from the wife and the victim, but it was denied by the trial court. Pretrial and trial dates were set, but the wife and the victim did not appear. Despite the absence of the witnesses, the trial court ordered the trial to proceed and set further hearing dates.

During the trial, the prosecution presented testimonies from NBI agents and a Medico-Legal Officer, as well as exhibits such as a complaint sheet, sworn statements, and a medical certificate. The defense objected to the admission of the exhibits, arguing that they were hearsay and lacked corroboration. The trial court admitted the exhibits as exceptions to the rule and denied the defense's motion to reconsider.

The court also denied the accused's demurrer to evidence, and the accused waived his right to present evidence. The trial court found the accused guilty of rape and sentenced him to death. The accused filed an appeal, claiming errors on the part of the trial court including the admission of hearsay evidence and the failure to prove guilt beyond reasonable doubt.

During the trial, it was established that the complainants were no longer interested in pursuing the criminal complaint against the accused. The Office of the Solicitor General agreed with the trial court and prayed for the affirmation of the decision. The accused waived the filing of a Reply Brief. The case was deemed submitted for decision. The accused must be acquitted as the evidence for the prosecution failed to meet the required proof beyond reasonable doubt.

ISSUES:

  1. Whether the trial court erred in not dismissing the criminal complaint against the appellant for lack of interest to prosecute.

  2. Whether the trial court erred in admitting the hearsay testimony of the prosecution witnesses.

  3. Whether the trial court erred in rendering a verdict of conviction despite the alleged insufficient evidence.

RULING:

  1. The Supreme Court ruled that the trial court did not err in not dismissing the criminal complaint based solely on the affidavit of desistance. However, it held that the trial court should have dismissed the case due to the failure of the prosecution to meet the quantum of proof required in criminal cases.

  2. The Supreme Court ruled that the testimonies of the NBI agents and the medical officer contained inadmissible hearsay since the agents had no personal knowledge as to what actually and truthfully happened. The court also ruled that the trial court erred in admitting the sworn statements as part of the res gestae since they were not made immediately after the occurrence of the alleged crime.

  3. The Supreme Court found that the prosecution's evidence failed to prove the appellant's guilt beyond reasonable doubt, and thus acquitted the accused.

PRINCIPLES:

  • Presumption of Innocence: Accused is entitled to acquittal unless guilt is shown beyond reasonable doubt.

  • Hearsay Rule: A witness can only testify to facts within their personal knowledge. Statements made to an investigating officer are generally considered hearsay if the affiant does not testify in court.

  • Res Gestae: Statements must be made spontaneously during or immediately after a startling event to be considered as part of the res gestae.

  • Affidavit of Desistance: Affidavit of desistance filed after the institution of a criminal action cannot be a ground for dismissal.

  • Burden of Proof: In criminal cases, the prosecution must meet the burden of proof beyond reasonable doubt.

  • Article 335 of the Revised Penal Code (as amended by R.A. No. 7659): Specifies that if the victim is under eighteen and the offender is a parent, the death penalty may be imposed.

  • Correct Information in Charges: Prosecutors must accurately refer to appropriate statutes and amendments to avoid prejudicial legal repercussions.