Gracer Erick D.

Enriquez
LIB 1-E
PEOPLE vs. RITTER
194 SCRA 690

FACTS:
On or about October 10, 1986, accused Ritter brought Jessie Ramirez and Rosario
Baluyot inside his HOTEL ROOM in Olongapo City. Inside the HOTEL ROOM, the
accused told them to take a bath. When Rosario came out of the bathroom, she was
told to remove her clothes by the accused and to join him in bed. At that time,
Jessie was already asleep but Rosario touched him to call his attention. When he
looked, he saw the accused placing his penis against the vagina of Rosario and that
he was trying to penetrate but it would not fit.
The following morning the accused left after paying the children. Rosario then told
Jessie that the accused inserted something in her vagina. Sometime the following
day, Jessie saw Rosario and he asked her whether the object was already removed
from her body and Rosario said "Yes". However, Jessie claimed that on the evening
of that same date, he saw Rosario and she was complaining of pain in her vagina
and when he asked her, she said that the foreign object was not yet removed.
Seven months later, Rosario was brought to the hospital with bloodied skirt,
unconscious and foul smelling.
After 6 days, Rosario got serious and was pronounced dead subsequent to her
operation with a portion of a sexual vibrator extracted from her vagina. A case for
Rape with Homicide was filed against Ritter.
The Regional Trial Court of Olongapo rendered a decision declaring him guilty
beyond reasonable doubt citing the rationale of Art 4 of the Revised Penal He who
is the cause of the cause is the cause of the evil caused. The Supreme Court
however, reversed the judgment of the lower court and acquitted Ritter.

ISSUE:
Whether or not the acquittal of the accused in a criminal case also releases him
from civil liability.

HELD:
No. The prosecution failed to prove that Rosario was only 12 years old when the
incident with Ritter happened. And that Rosario prostituted herself even at the
tender age. As evidence, she received 300 from Ritter the following morning. A
doctor/specialist also testified that the inserted object in the vagina of Rosario
Baluyot by Ritter was different from that which caused her death. As evidence,
Rosario herself said to Jessie the following day that the object has been removed
already. She also told the doctor that a Negro inserted it to her vagina 3 months
ago. Ritter was a Caucasian. Ritter was also acquitted for the criminal case of rape
with homicide. However, it does not exempt him for the moral and exemplary
damages he must award to the victims heirs. It does not necessarily follow that the
appellant is also free from civil liability which is impliedly instituted with the criminal
action. Ritter was deported.

PEOPLE VS. GENOSA

G.R. NO.135981

FACTS:
That Marivic Genosa, the Appellant on the 15November1995, attacked and
wounded his husband, which ultimately led to his death. According to the appellant
she did not provoke her husband when she got home that night it was her husband
who began the provocation. The Appellant said she was frightened that her husband
would hurt her and she wanted to make sure she would deliver her baby safely. In
fact, The Appelant had to be admitted later at the Rizal Medical Centre as she was
suffering from eclampsia and hypertension, and the baby was born prematurely on
December 1, 1995.
The Appellant testified that during her marriage she had tried to leave her husband
at least five (5) times, but that Ben would always follow her and they would
reconcile. The Apellant said that the reason why Ben was violent and abusive
towards her that night was because 'he was crazy about his recent girlfriend, Lulu
Rubillos.
The Appellant after being interviewed by specialists, has been shown to be
suffering from Battered Woman Syndrome.
The appellant with a plea of self defense admitted the killing of her husband, she
was then found guilty of Parricide, with the aggravating circumstance of treachery,
for the husband was attacked while asleep.

ISSUE:
Whether or not the appellant can validly invoke the battered woman syndrome as
constituting self.

HELD:
Yes. The court ruled against the appellant as she failed to prove that she is afflicted
with the battered woman syndrome.
A battered woman is characterized as a woman who is repeatedly subjected to any
forceful physical or psychological behavior by a man in order to coerce her to do
something he wants her to do without concern for her rights. Such women include
wives or women in any form of intimate relationship with men. In order to be
classified as a battered woman, the couple must go through the battering cycle at
least twice. A woman who finds herself in a violent situation more than once and
remains in such situation is defined as a battered woman.