People vs Mateo [G.R No. 147678-87] Case Digest

 

People vs Mateo

G.R No. 147678-87

 

Facts:

Ten informations for the crime of rape allegedly committed on ten different dates were filed againts appellant Efren Mateo filed in RTC Tarlac. Private complainant testified that during the rape incidents she was gagged with a handkerchief which rendered her unable to shout for help.  Later on, however, she gave different versions on whether appellant covered her mouth with his hand or with a handkerchief during the two rape incidents. Eventually, she repudiated her earlier testimony by stating that appellant had never covered her mouth, either with a handkerchief or with his hand. Also quite telling were some discrepancies in the testimony of private complainant regarding the whereabouts of her mother Rosemarie Capulong on the dates of the incidents. 

RTC found the appellant appellant guilty beyond reasonable doubt of ten (10) counts of rape.

 

Issue:

Whether or not SC has the rule-making power in adding an intermediate appeal or review in favor of the accused.

 

Held:

Yes.

 

Ratio:

Supreme Court has assumed the direct appellate review over all criminal cases in which the penalty imposed is death, reclusion perpetua or life imprisonment pursuant to Art. 8, Sec. 5 of 1987 Philippine Constitution. However, that the constitutional provision is not preclusive in character, and it does not necessarily prevent the Court, in the exercise of its rule-making power, from adding an intermediate appeal or review in favor of the accused.

In passing, during the deliberations among the members of the Court, there has been a marked absence of unanimity on the crucial point of guilt or innocence of herein appellant.  Some are convinced that the evidence would appear to be sufficient to convict; some would accept the recommendation of acquittal from the Solicitor General on the ground of inadequate proof of guilt beyond reasonable doubt.  Indeed, the occasion best demonstrates the typical dilemma, i.e., the determination and appreciation of primarily factual matters, which the Supreme Court has had to face with in automatic review cases; yet, it is the Court of Appeals that has aptly been given the direct mandate to review factual issues.