Facts:

Accused-appellant Victorino del Mundo was charged with six counts of rape against his ten-year-old daughter, Marivic del Mundo, in the Regional Trial Court (RTC) of Cabanatuan City. The incidents occurred on different days in October 1993, with one incident occurring on July 22, 1994. The charges were filed in August 1994, and the court noted that only one of the cases (Criminal Case No. 5983) fell under Republic Act No. 7659, which imposed the death penalty for certain heinous crimes, including rape of a minor by a parent.

The prosecution's case included the testimony of Dr. Jun Concepcion, the City Health Officer, who conducted a medico-legal examination of Marivic. His report indicated signs of vaginal penetration, including abrasions and a ruptured hymen. The prosecution presented this evidence alongside testimonies from other witnesses.

In defense, Marivic herself testified and presented an affidavit of desistance, stating that she no longer wished to pursue the case against her father, claiming that the incidents were the result of a misunderstanding and that they had reconciled. Despite this affidavit, the trial court convicted Victorino del Mundo, sentencing him to reclusion perpetua for five of the counts and death for the sixth.

The case was automatically elevated to the Supreme Court for review. Subsequently, Victorino del Mundo's counsel filed a motion for a new trial, citing newly discovered evidence, irregularities during the trial, and the recantation of Marivic's testimony.

Legal Issues:

  1. Whether the recantation of the complainant's testimony and the new medical evidence warranted a new trial.
  2. The implications of the discrepancies between the medico-legal reports regarding the alleged rape.
  3. The legal standards for granting a motion for a new trial in criminal cases.

Arguments:

  • For the Accused-Appellant:

    • The defense argued that the recantation of Marivic's testimony, along with the new medical report from the NBI indicating that her physical virginity was preserved, constituted new and material evidence that could potentially change the outcome of the trial.
    • They contended that the discrepancies between the two medico-legal reports raised substantial doubt about the accused's guilt, warranting a new trial in the interest of justice.

  • For the Prosecution:

    • The prosecution maintained that the original medico-legal report by Dr. Concepcion was credible and supported the conviction. They argued that the recantation of the victim's testimony should not be given weight, as it could be influenced by external factors, including familial pressure.

Court's Decision and Legal Reasoning:

The Supreme Court granted the motion for a new trial, setting aside the judgment of conviction. The Court emphasized the importance of substantial justice, particularly given the serious nature of the charges and the death penalty imposed. The Court noted the significant discrepancies between the two medico-legal reports, which raised doubts about the accused's guilt.

The Court highlighted that the rules for granting a new trial should be liberally construed to allow for a just determination of rights. It reiterated that the primary goal of court proceedings is to search for the truth and that technicalities should not obstruct the administration of justice. The Court cited previous jurisprudence that allowed for new trials based on recantation of testimony and other grounds not explicitly mentioned in the statute.

The case was remanded to the trial court for a new trial, allowing the accused to present additional evidence in his defense.

Significant Legal Principles Established:

  1. The importance of substantial justice in criminal proceedings, especially in cases involving severe penalties such as death.
  2. The Court's discretion to grant a new trial based on recantation of testimony and discrepancies in evidence, emphasizing that the rules of court should aid rather than obstruct justice.
  3. The recognition that the search for truth in judicial proceedings may necessitate a liberal interpretation of procedural rules to ensure that all parties have the opportunity to present their case fully.