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    2 - People Vs Magpayo

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    Rose Mary G. Enano
    Benjamin C. Magpayo was charged with rape, robbery, and forcible abduction with rape against multiple minors. He claimed the trial court erred in allowing evidence from one case to be used in another. The Supreme Court upheld the trial court's ruling, finding the evidence was properly admitted to show Magpayo's modus operandi or common scheme. Specifically, the Court found Magpayo's pattern was to target young girls under 12, isolate them, then commit sexual and other crimes. This similarity allowed evidence from one case to be used in another per Section 34 of the Rules on Evidence regarding similar acts. The Court affirmed the convictions.

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    2 - People Vs Magpayo

    Uploaded by

    Rose Mary G. Enano
    198 views1 page
    Benjamin C. Magpayo was charged with rape, robbery, and forcible abduction with rape against multiple minors. He claimed the trial court erred in allowing evidence from one case to be used in another. The Supreme Court upheld the trial court's ruling, finding the evidence was properly admitted to show Magpayo's modus operandi or common scheme. Specifically, the Court found Magpayo's pattern was to target young girls under 12, isolate them, then commit sexual and other crimes. This similarity allowed evidence from one case to be used in another per Section 34 of the Rules on Evidence regarding similar acts. The Court affirmed the convictions.

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    Benjamin C. Magpayo was charged with rape, robbery, and forcible abduction with rape against multiple minors. He claimed the trial court erred in allowing evidence from one case to be used in another. The Supreme Court upheld the trial court's ruling, finding the evidence was properly admitted to show Magpayo's modus operandi or common scheme. Specifically, the Court found Magpayo's pattern was to target young girls under 12, isolate them, then commit sexual and other crimes. This similarity allowed evidence from one case to be used in another per Section 34 of the Rules on Evidence regarding similar acts. The Court affirmed the convictions.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    198 views1 page

    2 - People Vs Magpayo

    Uploaded by

    Rose Mary G. Enano
    Benjamin C. Magpayo was charged with rape, robbery, and forcible abduction with rape against multiple minors. He claimed the trial court erred in allowing evidence from one case to be used in another. The Supreme Court upheld the trial court's ruling, finding the evidence was properly admitted to show Magpayo's modus operandi or common scheme. Specifically, the Court found Magpayo's pattern was to target young girls under 12, isolate them, then commit sexual and other crimes. This similarity allowed evidence from one case to be used in another per Section 34 of the Rules on Evidence regarding similar acts. The Court affirmed the convictions.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    G.R. Nos.

    92961-64 September 1, 1993 In the case at bar,


    THE PEOPLE OF THE PHILIPPINES evidence was introduced in Criminal Case No. 6443
    vs. (Forcible Abduction with Rape) committed by
    BENJAMIN C. MAGPAYO, appellant against 11-year old Mara N. Chico on
    November 20, 1987, not as evidence of similar acts to
    Benjamin C. Magpayo was charged prove that on April 10, 1988, the said appellant also
     Criminal Case No. 6436 (RAPE)- minor who is committed a similar act of rape (and robbery) against
    under 11 years old. the person of 10-year old Lilibeth Bobis (Criminal Case
     Criminal Case No. 6437 (ROBBERY) No. 6436 rape).
     Criminal Case No. 6438 (ROBBERY WITH
    HOLD-UP) These offenses are separate crimes and are the
     Criminal Case No. 6443 (FORCIBLE subject of separate complaints and proofs though
    ABDUCTION WITH RAPE)- 12 years of age jointly tried.
    before the Regional Trial Court of Malabon was found
    guilty of all the offenses charged. Hence, the evidence in one was not offered and
    admitted to prove the other but only to show the
    Benjamin C. Magpayo assails the application of the plan, scheme or modus operandi of the offender.
    doctrine of res inter alios acta (Sec. 34, Rule 130 of the
    Revised Rules of Evidence) allegedly because the As aptly noted by the trial court:
    similarity of the acts involved (i.e., molestation) was It is to be observed that in all the
    not sufficiently established. above-entitled cases, the modus
    operandi of the offender is that of
    After careful review of the records before us, we hold approaching young girls of not
    that the trial court committed no error in applying the more than twelve years of age,
    exception to the above doctrine. The Rules provide: and taking advantage of their
    Sec. 34. Similar acts as evidence.  — innocence, imputed to them the
    Evidence that one did or did not a commission of a crime and
    certain thing at one time is not brought them to an isolated place
    admissible to prove that he did or where the offenses charged were
    did not do the same or similar thing committed. These young girls
    at another time;  but it may be narrated in detail in a clear and
    received to prove a specific intent or convincing manner what the
    knowledge, identity, plan, system, offender did to them and likewise
    scheme, habit, custom or usage, and positively identified said offender as
    the like  (Emphasis supplied.) herein accused during the
    investigation at the Malabon Police
    As a general rule: Station on May 22, 1988
    rule, evidence is not admissible which shows or tends immediately after the arrest of the
    to show, that the accused in a criminal case has accused, as well as during the trial.
    committed a crime wholly independent of the offense Thus, Section 34, Rule 130 of the
    for which he is on trial. It is not competent to prove Revised Rules of Evidence provides
    that he committed other crimes of a like nature for that evidence that one did or did
    the purpose of showing that he committed the crime not do a certain thing at one time
    charged in the complaint or information. may be received to prove a specific
    intent or knowledge, identity, plan,
    exception system, scheme, habit, custom or
    when such evidence tends directly to establish the usage and the like. (Rollo, p. 28;
    particular crime, and it is usually competent to prove Joint Decision, p. 6)
    the motive, the intent, the absence of mistake or
    accident, a common scheme or plan embracing the
    commission of two or more crimes so related to each
    other that proof of one tends to establish the other,
    or the identity of the person charged with the
    commission of the crime on trial.

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