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PEOPLE v. ENDRICO GALAS

This case has been cited 3 times or more.

	GR Nos. 148397-400 2004-07-07	PEOPLE v. NICODEMO MINON TINGA, J,
In the present case, while the age of the private complainants at the time of the rape was indicated in the Informations, the prosecution was not able to establish their age during trial. The record of the case is bereft of any independent evidence, such as the private complainants' duly certified Certificate of Live Birth, accurately showing their respective ages. A careful perusal of the TSN reveals that when private complainants were placed on the witness stand, the matter of their age at the time of the rape was not even discussed. At most, their ages were mentioned only at the beginning of their testimonies describing their personal circumstances. In People v. Galas,[56] we held that we cannot consider a rape victim's statement at the beginning of her testimony describing her personal circumstances as proof of age beyond reasonable doubt that the Court has considered indispensable in the criminal prosecution of cases involving the extreme penalty of death. So it must be in the instant case.
	GR No. 155511-22 2004-04-14	PEOPLE v. MARIO ODEN VITUG, J.
While the records of the case are indeed bereft of any indication that the rule has sufficiently been complied with, the evidence for the prosecution outside of the plea of guilt, nevertheless, would adequately establish the guilt of appellant beyond reasonable doubt.[9] The manner by which the plea of guilt is made, whether improvidently or not, loses much of great significance where the conviction can be based on independent evidence proving the commission by the person accused of the offense charged.[10]
	GR No. 155511-22 2004-04-14	PEOPLE v. MARIO ODEN VITUG, J.
In People vs. Galas,[17] the Court has held:"To justify the imposition of death, proof of the victim's age is indubitable. There must be sufficient and clear evidence proving her age, even if not denied by the accused. A duly certified certificate of his birth accurately showing the complainant's age or some other authentic document such as a baptismal certificate or a school record, has been recognized as competent evidence.