G.R. No.

177357 : October 17, 2012

PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. VAL DELOS REYES, Accused-
Appellant.
Issue:
Whether or not the RTC erred in holding Delos Reyes guilty beyond reasonable doubt of the crime
of rape when the witnesses in the trial of Delos Reyes merely affirmed their testimonies given on
the direct examination in the trial of Go while Delos Reyes was still at large.
Facts of the Case:
On the 30th of March, 1995, Delos Reyes and Donel Go were charged with three counts and two
counts of rape, respectively, in three separate informations. The evidence of the prosecution
established that on December 22, 1994, at around 4:00 o’clock in the afternoon, the victim was
requested by her sister to deliver the pictures taken during the christening of her niece to Go, one
of the godfathers. The victim and her sister then left the house on board a tricycle. The victim
dropped off her sister at the Philtranco bus terminal and proceeded to the house of Go in San
Roque, Tabaco City, to deliver the pictures.
Arriving at the place, the victim saw Go standing by the roadside talking to a man, who was later
introduced to her as Delos Reyes. According to AAA, there was a sudden downpour before she
could leave. Upon invitation of Go, she took shelter in his house. She noticed that there was nobody
in the house. Alarmed and fearful, she tried to leave despite the pouring rain but Go stopped her
by forcibly pulling her. Go and Delos Reyes were able to have carnal knowledge with the victim
by means of force when they were able to let the victim drink two bottles of beer by also forcing
the victim’s mouth open while they poured the beer into her mouth. The victim was then
successively raped in a nearby construction site.
When the private complainant elevated the case to the authorities, Delos Reyes was at large at that
time, only Go was arraigned. Before the prosecution could finish presenting evidence, Go jumped
bail and was tried in absentia. When Delos Reyes was apprehended by the police in 1997, the
RTC ordered the revival of the cases against Delos Reyes. On December 3, 1997, the cases against
him were transferred to RTC-Br. 15, which was designated by this Court as a special court to try
cases involving heinous crimes.
The prosecution adopted the marked evidence that included the testimonies of the prosecution
witnesses, particularly those of the victim, her mother, her sister, an Dr. Marissa S. Saguinsin who
examined the victim. The RTC then found Delos Reyes guilty beyond reasonable doubt of three
counts of rape and sentenced him to suffer the penalty of reclusion perpetua.

Ruling:
The Court held that since Delos Reyes actively participated in the trial of the case through
presenting evidence for his defense and cross-examined the prosecution witnesses, it is now too
late for him to declare that his right to be informed of the nature and cause of the accusation was
violated. It is not the designation of the offense in the Information that governs, rather it is the
allegations that must be considered in determining what crime is charged.
The denial of Delos Reyes’ motion to have an ocular inspection of the site where in the crime was
committed was held to be of scant consideration by the court. It has been said that ocular inspection
rests within the sound discretion of the court. Inspection may be granted only where it is reasonably
certain that it will be of substantial aid to the court in reaching a correct verdict. The trial court in
this case correctly refused to make the inspection where testimonial evidence adequately pictured
the condition of the place. Thus, a view of the place would serve no useful purpose. The long
lapse of time since the rape would have meant that the construction site would have been finished.