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Bangayan Acquittal: Evidence Exclusion

The document summarizes a court case where Bangayan was found guilty of statutory rape of AAA based on witness testimony and medical evidence. However, the court ultimately acquitted Bangayan because a key piece of evidence, a social case study report on AAA, was not properly authenticated or formally offered during trial, depriving Bangayan of due process.

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226 views2 pages

Bangayan Acquittal: Evidence Exclusion

The document summarizes a court case where Bangayan was found guilty of statutory rape of AAA based on witness testimony and medical evidence. However, the court ultimately acquitted Bangayan because a key piece of evidence, a social case study report on AAA, was not properly authenticated or formally offered during trial, depriving Bangayan of due process.

Uploaded by

chrstnzeun
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Bangayan vs. People, 954 SCRA 392, G.R. No.

235610 September 16, 2020

FACTS: On January 5, 2012, BBB found Bangayan on top of AAA, both naked waist down.
Bangayan threatened BBB. On April 24, 2012, AAA reported to police with her aunt CCC. Dr. Villar
confirmed signs of intercourse and pregnancy, with AAA admitting prior relations with Bangayan.
AAA gave birth to a baby boy on October 2, 2012. During arraignment on September 4, 2014, AAA's
affidavit stated she wouldn't pursue charges due to her relationship with Bangayan. Another child
was born on May 4, 2015. Bangayan found guilty under R.A. 7610. The RTC dismissed AAA's
consent due to her age and Bangayan's influence. Affidavit deemed hearsay. Bangayan claimed a
consensual relationship, akin to Article 266-C of R.A. 8353, justifying acquittal for the sake of their
family. Bangayan's appeal denied by the Court of Appeals. AAA did not testify during the trial. The
Social Case Study Report reflecting the evaluation of Social Welfare Officer III Theresa A. Mauricio
(Mauricio) on AAA’s social, emotional, and intellectual development and reported that the client
suffered multiple emotional crisis that hampered her growth and development.

ISSUE: Whether the Social Case Study Report be admitted and be given credence by the Court.

RULING: NO. Section 34.Offer of evidence - The court shall consider no evidence which has not
been formally offered. The purpose for which the evidence is offered must be specified. A careful
study of the records reveals that the RTC received the Social Case Study Report dated September
25, 2014 on October 8, 2014. Although the testimony of the social worker was included in the Pre-
Trial Order, the document was never properly identified, authenticated by the social worker who
prepared the report, and included in the formal offer of evidence. The social worker never testified in
open court and the defense was never given an opportunity to test her credibility and verify the
correctness and accuracy of her findings. To Our mind, giving credence to evidence which was not
formally offered during trial would deprive the other party of due process. Thus, evidence not
formally offered has no probative value and must be excluded by the court. Furthermore, even
assuming that the Social Case Study Report was properly presented and formally offered, it cannot
be made the basis for establishing the absence of AAA’s sexual consent. Due to the prosecution’s
failure to establish and prove beyond reasonable doubt the requisites for the charge of violation of
Section 5(b) of R.A. 7610, Bangayan must be acquitted.

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