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PEOPLE v. EFREN VALEZ

This case has been cited 6 times or more.

	GR No. 176634 2010-04-05	PEOPLE v. ROMEO MIRANDA Y MICHAEL LEONARDO-DE CASTRO, J.
Under Article 266-B of the Revised Penal Code, as amended by Republic Act No. 8353, minority and relationship are special qualifying circumstances in the crime of rape that warrant the mandatory penalty of death. As such, they must both be specifically pleaded in the Information and proven during trial. These two circumstances, minority and relationship, must concur; otherwise, if only one is proven during trial, even if the Information alleged both, the death penalty cannot be imposed. And, as special qualifying circumstances, the same must be proven beyond reasonable doubt as the crime itself.[25]
	GR No. 172967 2007-12-19	PEOPLE v. CHRISTOPHER AVILES CHICO-NAZARIO, J.
Qualifying circumstances must be proven beyond reasonable doubt as the crime itself.[17] It cannot be considered on the strength of evidence which merely tends to show that the victim was probably surprised to see the assailant trying to get inside the jeepney. As discussed above, Arenas' shout can be interpreted in different ways. In fact, prosecution witness Dr. Ramon Gonzales even testified that it was possible that Aviles and Arenas were having a fight: Atty. Florendo: You also found a wound on the left wrist of the cadaver, Doctor? A: Yes sir.
	GR No. 141123 2002-07-23	PEOPLE v. NICOMEDES CANON PER CURIAM
"fn">[23] Genelyn's minority was also sufficiently established by her mother's testimony[24] even though the prosecution failed to present her birth certificate or other documentary evidence such as her baptismal certificate, or school records in lieu thereof. In the cases of People vs. Valez,[25] and People vs. dela Cruz,[26] the Court held that the testimony of the victim's mother that her child was still a minor at the time of the rape sufficiently proved the victim's minority, since as a mother she is presumed to have personal knowledge of the age of her child. Moreover, accused-appellant himself admitted in his testimony that in January 1996, Genelyn was only nine years old: xxx
	GR Nos. 136867-68 2001-09-24	PEOPLE v. RODRIGO GALVEZ Y JEREZ YNARES-SANTIAGO, J.
The two circumstances of minority and relationship must concur; otherwise, if only one is proven during trial, even if the complaint or information alleged both, the death penalty cannot be imposed.[38]
	GR Nos. 129530-31 2001-09-24	PEOPLE v. WILFREDO OLARTE PER CURIAM
"It must be pointed out that in cases of rape, complainant's testimony must be considered and calibrated in its entirety, and not by truncated portions or isolated passages thereof."[23] In this case, the Court finds complainant's testimony worthy of credit.
	GR No. 132714 2001-09-06	PEOPLE v. RENATO LALINGJAMAN YNARES-SANTIAGO, J.
The two circumstances of minority and relationship must concur; otherwise, if only one is proven during trial, even if the complaint or information alleged both, the death penalty cannot be imposed.[38] With regard to the qualifying circumstance of minority: This Court has always decreed that the burden to prove the minority age of the victim as of the date of the rape is on the prosecution. As minority age is a qualifying circumstance, it must be proved with equal certainty and clearness as the crime itself.[39] There must be independent evidence proving the age of the victim, other than the testimonies of the prosecution witnesses and the absence of denial by the accused.[40] Where there is no evidence at all of the minority age of the victim or where the evidence was weak and unreliable and insufficient, this Court was impelled not to impose the death penalty.[41]