Name: Magno, Miko G.

Date: May 14, 2023

Course & Year & Section: BS CRIMINOLOGY 3A
People of the Philippines vs. Amado Daniel alias Amado Ato (Supreme Court Reports Annotated
(SCRA). Vol 86, pp. 511-541. (Rape)
Subject Matter: Use of polygraph machine / lie detector and other means of coercing information.
Summary of the case: Amado Daniel raped Margarita Paleng inside her boarding house in Baguio
City. Margarita filed a complaint against Daniel. During trial Daniel voluntarily submitted to lie
detector test with the NBI. In said test, Daniel was asked whether he forced Margarita into having
sexual intercourse with him, he answered “no”. the result of the test was in the appellant’s favor.
Nonetheless, the CFI found Daniel guilty of rape and was affirmed by CA. when elevated to the SC,
Daniel’s counsel raised that the lie detector test result was favorable to Daniel’s to support Daniel
claim’s that that margarita consented. The SC affirmed Daniel’s conviction.
Doctrine: The Court does not put much faith and credit on it. It is well known that the same is not
conclusive. Its efficacy depends upon the time, place and circumstances when taken and the nature
of the subject. If subject is hard and the circumstances, as in this instant, were not conducive to
affect the subject emotionally, the test will fail.
The subject had nothing more to fear because the trial was over. He was not confronted by
the victim or other persons. Whom he had a reason to fear. Naturally, his reaction to the questions
propounded was normal and unaffected and the apparatus could not detect it.
Facts on the Case: Margarita Paleng was 13 years old native of Mountain Province. She was
boarding at a house located in Baguio City, as she then a first-year high school student of Baguio
Eastern High. September 20, 1965 - at about three o'clock in the afternoon, she had just arrived in
the City from Tublay in a Dangwa bus. The accused, a co-passenger, followed her to her boarding
house and succeeded in having carnal knowledge by threatening her with a dagger. Margarita lost
consciousness. When she recovered, he was already gone. The following morning, herfather came to
visit her. She confided to him the terrible misfortune. She was immediately brought to the Baguio
General Hospital where she was examined. Then they proceeded to the Police Department. The
Chief of Police accompanied them to the Health Center where she was again examined by Dr.
Perfecto O. Micu who thereafter submitted his medical report certifying that there was a recent
defloration. Margarita and her father gave their respective statements before the police authorities.
She signed her criminal complaint prepared by the Fiscal's Office of Baguio.
She filed a complaint accusing Daniel of rape.
Daniel's defense: He and Margarita were acquainted with each other since 1963, and there
were occasions when they rode together in a bus; that the incident of September 20, 1965 inside
the room of Margarita was with the latter's consent, and in fact it was the second time he had
carnal knowledge with her, the first time having occurred inside a shack; that he promised
Margarita that he would marry her, but to his surprise, she filed the instant complaint against him.
At the time of trial in 1965, appellant voluntarily submitted to a lie detector test with the National
Bureau of Investigation and the report of the lie detector examiner was in the appellant's favor, that
is the latter was telling the truth on the questions propounded to him one of which was whether he
forced Margarita into having sexual intercourse with him and the reply was "No."
CFI-Baguio: Nonetheless, the accused was found guilty of rape. MR and Request for new trial
denied.
Court of Appeals: The accused was found guilty of rape.
Holding: Generally, in a case of this nature (rape), the evidence of the prosecution consists solely of
the testimony of the offended party. In this case, the declaration of the victim, who at the time of the
incident was a little less than 13 years old, on the basis of which the trial court found the charge of
rape duly established.
Appellant assails the veracity of the testimony of the complainant. A public trial involving a
crime of this nature subjects the victim to what can be a harrowing experience of submitting to a
physical examination of her body, an investigation by police authorities, appearance in court for the
hearing where she has to unravel lewd and hideous details of a painful event which she would
prefer to forget and leave it unknown to others. If Margarita did forego all these and preferred to
face the cruel realities of the situation it was due to her simple and natural instincts of speaking out
the truth.
There is no possible motive for a thirteen-year old girl barely in her teens to fabricate a story
that could only bring down on her and her family shame and humiliation and make her an object of
gossip and curiosity among her classmates and the people of her hometown.
Jesusa Reyes and Conrado B. Reyes vs. Bank of the Philippine Islands (BPI). (Criminal case No.
91-3453 in the RTC of Pasig Branch 142 MM)
FACTS: Reyes decided to open new bank accounts in BPI. 200k will be transferred from her
previous account to the new account. However, the bank teller informed her that the balance is
insufficient, hence she decided that only 100k will be transferred and she would just deposit the
100k cash to have a 200k total bank deposit in the new account. She signed the edited withdrawal
slip to effect the transfer of 100k. She then left the premises of the bank. Afterwards, she instructed
her employee to update her passbook in the bank. The latter informed her that the deposit slip is
altered from 200k to 100k, that her balance in the new account is only 100k and not 200k. She
demanded then the money contending that aside from the 100k fund transfer, she also had
deposited 100k cash to the new account. In their reply, the BPI alleged that reyes left tha banks
premises without giving the 100k cash and that she did not sign the verification for the deposit
hence the bank alone entered the same in their record.
Defendant further claimed that when they subjected Cicero Capati to a lie detector test, the
latter passed the same with flying colors (Exhs. "5" to "5-C"), indicative of the fact that he was not
lying when he said that there really was no cash transaction involved when plaintiff Jesusa Reyes
went to the defendant bank on December 7, 1990; defendant further alleged that they even went to
the extent of informing Jesusa Reyes that her claim would not be given credit (Exh. "6") considering
that no such transaction was really made on December 7, 1990. 4
On August 12, 1994, the RTC issued a Decision 5 upholding the versions of respondents, the
dispositive portion of which reads:
WHEREFORE, premises considered, the Court finds in favor of the plaintiff Jesusa P. Reyes and
Conrado Reyes and against defendant Bank of the Philippine Islands ordering the latter to:
1. Return to plaintiffs their P100,000.00 with interest at 14% per annum from December 7,
1990;
2. Pay plaintiffs P1,000,000.00 as moral damages;
3. Pay plaintiffs P350,000.00 as exemplary damages;
4. Pay plaintiffs P250,000.00 for and attorney's fees.6
ISSUE: won reyes presented sufficient evidence.
HELD: No. After a careful and close examination of the records and evidence presented by the
parties, we find that respondents failed to successfully prove by preponderance of evidence that
respondent Jesusa made an initial deposit of P200,000.00 in her Express Teller account.
 Respondent Jesusa signed the withdrawal slip. We find it strange that she would sign the
withdrawal slip if her intention in the first place was to withdraw only P100,000.00 from her
savings account and deposit P100,000.00 in cash with her.
Moreover, respondent Jesusa’s claim that she signed the withdrawal slip without looking at
the amount indicated therein fails to convince us, for respondent Jesusa, as a businesswoman in
the regular course of business and taking ordinary care of her concerns, would make sure that she
would check the amount written on the withdrawal slip before affixing her signature. Significantly,
we note that the space provided for her signature is very near the space where the amount of
P200,000.00 in words and figures are written; thus, she could not have failed to notice that the
amount of P200,000.00 was written instead of P100,000.00.
While the fact that the alteration in the original deposit slip was signed by Capati and not by
respondent Jesusa herself was a violation of the bank’s policy requiring the depositor to sign the
correction, nevertheless, we find that respondents failed to satisfactorily establish by preponderance
of evidence that indeed there was an additional cash of P100,000.00 deposited to the new Express
Teller account.
Physical evidence is a mute but eloquent manifestation of truth, and it ranks high in our
hierarchy of trustworthy evidence. We have, on many occasions, relied principally upon physical
evidence in ascertaining the truth. Where the physical evidence on record runs counter to the
testimonial evidence of the prosecution witnesses, we consistently rule that the physical evidence
should prevail.
In addition, to uphold the declaration of the CA that it is unlikely for respondent Jesusa and
her daughter to concoct a false story against a banking institution is to give weight to conjectures
and surmises, which we cannot to uphold the declaration of the CA that it is unlikely for
respondent Jesusa and her daughter to concoct a false story against a banking institution is to give
weight to conjectures and surmises, which we cannot countenance.