46 PEOPLE V.

SANTOS
Date: September 8, 2006 GR 172322 Ynares-
Santiago, J.
Article III Section 1, I. Procedural Due Process, Rica Aggabao
A. Judicial Proceedings, 2. Aspects of the
Proceedings
Petitioners: People of the Philippines Respondents: Rene Santos

Doctrine: Aspects of the Proceedings

- Judges can ask questions so as to facilitate the case, he is not merely a referee of
the parties.
Facts:

1. Rene Santos was charged with rape of a 5 year old girl, Veverly Ann Cabanes y
Mabalot.
2. The rape occurred in the afternoon between July 17-23, 1999 in Barangay Sulipat,
Apalit Pampanga. Veverly was playin in the north part of the Sulipat Bridge when
Santos took her to his house and thereafter had sexual intercourse with her.
3. Defendant’s Version: He was then working as a driver for Mirriam Maglalang. In the
days of July 17-23, he had alibi as he was allegedly working then and driving
Maglalang to Manila, Quezon City, and Makati. Other than those, he was working as a
jeepney driver.
4. The RTC Convicted Santos and imposed upon him the death penalty. He then went to
the CA which only affirmed the trial court decision. Thus, this appeal.
Issue/s: Ruling:
1. W/N his defense was not accorded proper consideration equal to 1. NO
that of Veverly. 2. NO
2. W/N trial judge erred in the questioning during the case.
Rationale/Analysis/Legal Basis:
1. Supreme Court accords great respect to the findings of the RTC and the CA.
Furthermore, the testimony of Veverly Clearly and positively identified the event and
the appellant. As a six year old, her testimony is given full credit. The Court holds that
testimonies of rape victims who are young and immature deserve full credence.
Additionally, the testimony of appellant’s wife is doubted by the Court as it comes
with emotional ties and interest.
a. Defense: it would be unnatural for such child to go to school next day after the
incident, and that victim was not seriously answering questions during the
trial. The Court holds that the reaction to the rape is unpredictable for victims,
especially a 6 year-old child.
b. Defense: it could have been either of Santos’ two sons instead of him. The
Court holds that only one whose degree of wickedness plumbs the deepest
depths of criminal perversity would put the guilt on the sons.
c. Defense: the charge could have been motivated by the ill-motive of the
victim’s mom. The Court holds that ill-motive is immaterial when there are
affirmative or consequential declarations of his guilt.
2. The Court holds trial judges are accorded a reasonable leeway in putting such
questions to witnesses as may be essential to elicit relevant facts to make the record
speak the truth. Additionally, questioning is given a wider latitude when it concerns a
child witness.