People v. Guinto

G.R. No.
131516 March 5, 2003
PEOPLE OF THE PHILIPPINES, plaintiff-appellee,

vs.
RONNIE RULLEPA Y GUINTO, accused-appellant.
FACTS:
On November 20, 1995, as Gloria was about to set the table for dinner at her house in
Quezon City, Cyra May, then only three and a half years old, told her, "Mama, si kuya
Ronnie lagay niya titi niya at sinaksak sa puwit at sa bibig ko."
"Kuya Ronnie" is accused-appellant Ronnie Rullepa, the Buenafes' house boy, who was
sometimes left with Cyra May at home.
Gloria asked Cyra May how many times accused-appellant did those things to her, to
which she answered many times. Pursuing, Gloria asked Cyra May what else he did to
her, and Cyra May indicated the room where accused-appellant slept and pointed at his
pillow.
As on the night of November 20, 1995 accused-appellant was out with Gloria's husband
Col. Buenafe,4 she waited until their arrival at past 11:00 p.m. Gloria then sent accused-
appellant out on an errand and informed her husband about their daughter's plaint.
Buenafe thereupon talked to Cyra May who repeated what she had earlier told her mother
Gloria.
When accused-appellant returned, Buenafe and Gloria verified from him whether what
Cyra May had told them was true. Ronnie readily admitted doing those things but only
once, at 4:00 p.m. of November 17, 1995 or three days earlier. Unable to contain her
anger, Gloria slapped accused-appellant several times.
Since it was already midnight, the spouses waited until the following morning to bring
accused-appellant to Camp Karingal where he admitted the imputations against him, on
account of which he was detained. Gloria's sworn statement was then taken.
The defense's sole witness was accused-appellant, who was 28 and single at the time he
took the witness stand on June 9, 1997. He denied having anything to do with the
abrasions found in Cyra May's genitalia, and claimed that prior to the alleged incident, he
used to be ordered to buy medicine for Cyra May who had difficulty urinating. He further
alleged that after he refused to answer Gloria's queries if her husband Buenafe, whom
he usually accompanied whenever he went out of the house, was womanizing, Gloria
would always find fault in him. He suggested that Gloria was behind the filing of the
complaint.
Finding for the prosecution, Branch 96 of the Quezon City RTC rendered judgment, the
dispositive portion of which reads:
WHEREFORE, judgment is hereby rendered finding accused RONNIE RULLEPA y

GUINTO guilty beyond reasonable doubt of rape, and he is accordingly sentenced to
death.
ISSUES:
Whether or not a person’s appearance is admissible as object evidence.
RULING:
YES. A person's appearance, where relevant, is admissible as object evidence, the same
being addressed to the senses of the court. Section 1, Rule 130 provides:
SECTION 1. Object as evidence. — Objects as evidence are those addressed to the

senses of the court. When an object is relevant to the fact in issue, it may be exhibited to,
examined or viewed by the court.
"To be sure," one author writes, "this practice of inspection by the court of objects, things
or persons relevant to the fact in dispute, has its roots in ancient judicial procedure." 39
The author proceeds to quote from another authority:
"Nothing is older or commoner in the administration of law in all countries than the
submission to the senses of the tribunal itself, whether judge or jury, of objects which
furnish evidence. The view of the land by the jury, in real actions, of a wound by the judge
where mayhem was alleged, and of the person of one alleged to be an infant, in order
to fix his age, the inspection and comparison of seals, the examination of writings, to
determine, whether they are (`)blemished,(') the implements with which a crime was
committed or of a person alleged, in a bastardy proceeding, to be the child of another,
are few illustrations of what may be found abundantly in our own legal records and
textbooks for seven centuries past."40 (Emphasis supplied.)
A person's appearance, as evidence of age (for example, of infancy, or of being under

the age of consent to intercourse), is usually regarded as relevant; and, if so, the
tribunal may properly observe the person brought before it. 41 Experience teaches that
corporal appearances are approximately an index of the age of their bearer, particularly
for the marked extremes of old age and youth. In every case such evidence should be
accepted and weighed for what it may be in each case worth. In particular, the outward
physical appearance of an alleged minor may be considered in judging his age; a contrary
rule would for such an inference be pedantically over-cautious.42 Consequently, the jury
or the court trying an issue of fact may be allowed to judge the age of persons in court by
observation of such persons.43 The formal offer of the person as evidence is not
necessary. The examination and cross-examination of a party before the jury are
equivalent to exhibiting him before the jury and an offer of such person as an exhibit is
properly refused.44

People v. Guinto

Uploaded by

Copyright:

Available Formats

People v. Guinto

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

People v. Guinto

Uploaded by

Copyright:

Available Formats

G.R. No.

131516 March 5, 2003

PEOPLE OF THE PHILIPPINES, plaintiff-appellee,

WHEREFORE, judgment is hereby rendered finding accused RONNIE RULLEPA y

SECTION 1. Object as evidence. — Objects as evidence are those addressed to the

A person's appearance, as evidence of age (for example, of infancy, or of being under

You might also like