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PEOPLE v. MANUEL MATRIMONIO Y PADILLA

This case has been cited 12 times or more.

2014-04-21
LEONARDO-DE CASTRO, J.
In the instant case, the prosecution was able to establish that the accused-appellant had carnal knowledge of AAA on January 17, 2005.  AAA narrated in a straightforward manner the harrowing details of how the accused-appellant had sexual intercourse with her.  Again, the RTC found credible and convincing AAA's testimony on this matter.  Likewise, the Court finds no cogent reason to disbelieve AAA's testimony, which was corroborated by the medical findings of Dr. Rivamonte and Dr. Arellano that the victim's hymen had "complete healed lacerations at 1, 3, 6, 9 o'clock position[s]."  We held in People v. Oden[19] that the "eloquent testimony of the victim, coupled with the medical findings attesting to her non-virgin state, should be enough to confirm the truth of her charges."  As to the manner by which the rape was committed, the accused-appellant's moral ascendancy over AAA takes the place of the force and intimidation that is required in rape cases.[20]
2010-11-23
MENDOZA, J.
The Court, however, deems it proper to increase the exemplary damages from P25,000.00 to P30,000.00 following jurisprudence[62] for all counts of rape.  Article 2230 of the New Civil Code provides that "in criminal offenses, exemplary damages as a part of the civil liability may be imposed when the crime was committed with one or more aggravating circumstances. Such damages are separate and distinct from fines and shall be paid to the offended party." Furthermore, in People v. Matrimonio,[63] the Court awarded exemplary damages to dissuade other fathers with perverse tendencies or aberrant sexual behavior from sexually abusing their own daughters.
2010-07-09
MENDOZA, J.
The award of exemplary damages is likewise proper.  As held in People v. Dalisay,[40] "being corrective in nature, exemplary damages, therefore, can be awarded, not only in the presence of an aggravating circumstance, but also where the circumstances of the case show the highly reprehensible or outrageous conduct of the offender."  In much the same way as Article 2230 of the Civil Code prescribes an instance when exemplary damages may be awarded, Article 2229, the main provision, lays down the very basis of the award. Thus, in People v. Matrimonio,[41] the Court imposed exemplary damages to deter other fathers with perverse tendencies or aberrant sexual behavior from sexually abusing their own daughters. Also, in People v. Cristobal,[42] the Court awarded exemplary damages on account of the moral corruption, perversity and wickedness of the accused in sexually assaulting a pregnant married woman. Recently, in People v. Cristino Cañada,[43] People v. Pepito Neverio[44] and People v. Lorenzo Layco, Sr.,[45] the Court awarded exemplary damages to set a public example, to serve as deterrent to elders who abuse and corrupt the youth, and to protect the latter from sexual abuse.  It must be noted that, in the said cases, the Court used as basis Article 2229, rather than Article 2230, to justify the award of exemplary damages. Indeed, the deplorable act of the accused in defiling his daughter must not go unpunished.
2009-11-25
NACHURA, J.
Being corrective in nature, exemplary damages, therefore, can be awarded, not only in the presence of an aggravating circumstance, but also where the circumstances of the case show the highly reprehensible or outrageous conduct of the offender. In much the same way as Article 2230 prescribes an instance when exemplary damages may be awarded, Article 2229, the main provision, lays down the very basis of the award. Thus, in People v. Matrimonio,[45] the Court imposed exemplary damages to deter other fathers with perverse tendencies or aberrant sexual behavior from sexually abusing their own daughters. Also, in People v. Cristobal,[46] the Court awarded exemplary damages on account of the moral corruption, perversity and wickedness of the accused in sexually assaulting a pregnant married woman. Recently, in People of the Philippines v. Cristino Cañada,[47] People of the Philippines v. Pepito Neverio[48] and The People of the Philippines v. Lorenzo Layco, Sr.,[49] the Court awarded exemplary damages to set a public example, to serve as deterrent to elders who abuse and corrupt the youth, and to protect the latter from sexual abuse.
2009-01-20
CHICO-NAZARIO, J.
As correctly argued by the appellee, the fact that AAA did not shout or make an outcry when there were nearby persons does not mean that she was not raped by Mahinay. The workings of the human mind under emotional stress are unpredictable; people react differently in such situations: some may shout; some may faint; some may be shocked into insensibility; others may openly welcome their intrusion.[14]
2007-08-02
QUISUMBING, J.
(b) the penalty of life imprisonment, when the law violated does not make use of the nomenclature of the penalties of the Revised Penal Code. (Emphasis supplied.) This Court also sustains the Court of Appeals' ruling that the award of damages by the RTC should be modified. Pursuant to prevailing jurisprudence,[20] the civil indemnity and moral damages to be awarded are P75,000 and P75,000, respectively, for each conviction of rape which is qualified by circumstances warranting the imposition of the death penalty; and P25,000 as exemplary damages for each conviction of rape[21] in light of the presence of the qualifying circumstances of minority and relationship. Hence, appellant should pay AAA P150,000 as civil indemnity, P150,000 as moral damages and P50,000 as exemplary damages.
2003-10-23
PER CURIAM
As stressed by the court a quo, Ma. Christine was a credible witness; her testimony deserved the highest credence. Although we have of late practically jettisoned this long standing rule that when a woman testifies that she has been raped she says in effect all that is necessary to constitute the commission of this crime, we are persuaded to apply this rule with even more vigor in the instant case when the culprit is a close relative,[12] the victim no less than the minor daughter of the accused. More so when even in ordinary rape cases the sole testimony of the victim may seal the fate of her ravisher provided that she and her testimony are worthy of belief.[13]
2003-10-08
PER CURIAM
Time and again, we stress the verity that in incestuous rape where the father/stepfather exercises moral dominance over his daughter/stepdaughter, the victim by the sheer force of this moral influence is reduced to a docile creature, vulnerable and submissive to the sexual depredations of her tormentor. People v. Matrimonio elucidates this point[15] -
2000-04-27
BELLOSILLO, J.
We note that the trial court did not award damages to the victim. Under prevailing jurisprudence, civil indemnity of P50,000.00 is automatically awarded to the offended party without need of further evidence other than the fact of the commission of the rape.[22] As regards moral damages, the requirement of proof of mental and physical suffering has been dispensed with since we recognize the victim's injury as being inherently concomitant with and necessarily resulting from the crime of rape to warrant the award per se,[23] which we also grant in the amount of P50,000.00. The amount of P25,000.00 for exemplary damages is imposed to deter other fathers with similar perverse tendencies or aberrant sexual behaviors from sexually abusing their own daughters.[24]