CDT 2C CARL JOHNWYNE LINGCORAN NOVEMBER 18, 2021

SEC 8/ CL 2023

PT on EVIDENCE (PROOF BEYOND REASONABLE DOUBT)

1. What was the decision of the Regional Trial Court (RTC)?

The Regional Trial Court found Ansano guilty beyond reasonable doubt of rape. The
decision was released on November 16, 2015 at Branch 26 RTC.

2. What was the ruling of the Court of Appeals in the appeal filed by the accused?

The appeal filed by the accused has been denied by the Court of Appeals. The court
sentenced the accused to suffer the penalty of Reclusion Perpetua without eligibility for
parole and to pay AAA the amount of Php75,000.00 as civil indemnity, Php75,000.00 as
moral damages, and another Php75,000.00 as exemplary damages, all with interest at
the rate of six percent (6%) per annum from the finality of this Decision until fully paid.

3. What are the legal issues in the case?

The issue of whether the RTC and the CA erred in convicting the accused-appellant.

4. How did the Supreme Court decided on the case? What was its ruling?

According to the Supreme Court, accused-appellant Teodoro Ansano y Calleja is

ACQUITTED of the crime charged on the ground of reasonable doubt, and was ordered
to be IMMEDIATELY RELEASED from detention unless he is being lawfully held for
another cause.

5. Did the prosecution prove the guilt of the accused beyond reasonable doubt? 

No. the prosecution was able to discuss the doubt on Ansano’s identity as the
perpetrator of the crime even though the issue was glaring in the records of the
case. And that the testimony of the prosecution was unable to pass the exacting test of
moral certainty that the law demands and the rules require to satisfy the prosecution’s
burden of overcoming appellant’s presumption of innocence.
6. What are the jurisprudential guidelines on out-of-court identification being
done by the police?

a. The witness’ opportunity to view the criminal at the time of the crime

b. The witness’ degree of attention at that time;

c. The accuracy of any prior description given by the witness;

d. The length of time between the crime and the identification;

e. The level of certainty demonstrated by the witness at the identification; and

f. The suggestiveness of the identification procedure.

7. What is the totality of the circumstances test?

The totality of circumstances test requires the Court to look at the following factors in

weighing the reliability of the out-of-court identification: (1) the witness’ opportunity to
view the criminal at the time of the crime; (2) the witness’ degree of attention at that
time; (3) the accuracy of any prior description given by the witness; (4) the length of
time between the crime and the identification; (5) the level of certainty demonstrated by
the witness at the identification; and (6) the suggestiveness of the identification
procedure.

8. What are the two requisites for conviction for a crime based on the decision of
the Supreme Court?

a. The testimony of the victim was unable to pass the exacting test of moral certainty
that the law demands and the rules require to satisfy the prosecution’s burden of
overcoming appellant’s presumption of innocence.

b. Neither the RTC nor the CA was able to discuss the doubt on Ansano’s identity as
the perpetrator of the crime even though the issue was glaring in the records of the
case.