MURAO, JOSE PEPITO III

I. Article III Section 14, Right to be Informed:

People v. Manansala G.R. 110974-81

Facts:
According to Jennifer Manansala, herein accussed-appellant Dante Manansala’s daughter, her father raped
her a handful of times from November 1 up to November 8, 1991. Initially, Jennifer Manansala said that
the rape occurred in a taho factory in Tondo, Manila where his father worked and resided. Jennifer, who
was only 14 at that time, narrated that her father took her from her mother’s house and that her father
brought her to a room at the upper portion of the taho factory to rape her. She also noted that she was
physically abused through hitting with a belt when she refused to undress and that her father gave her
money every time she was raped.
However, upon further inquiry, Jennifer said that only the first time she was raped, which was supposedly
on November 1, 1991, occurred in Tondo and that the other rape incidents were conducted in Tarlac where
her father stayed for All Saint’s Day until November 14, 1991. According to Jennifer, she only alleged that
all rape incidents occurred in Manila because she was afraid that the complaints would get dismissed by
virtue of lack of jurisdiction of the Manila court. She also clarified that she was called by her father’s niece
named Josephine and was told to go to his father’s workplace and not directly by his father. All this
information was affirmed by her mother Teresita, who was at that time, have been separated from Dante
Manansala since 1986. However, the testimony of Jennifer’s mother Teresita added a couple of
discrepancies to her account. For example, Teresita said that Jennifer was with Dante in Tarlac from
November 1 to November 13, thus, making the rape in the Manila taho factory on November 1 impossible.
Added to this, Teresita said that Jennifer only informed her of the rape incidents on November 16, which
contradicts the statement of Jennifer, that she told her mother on November 1, 1991. It is important to note
however that a medico-legal officer testified that after examination, he found that Jennifer was no longer a
virgin and that there were two lacerations in her private parts.
For his defense, Dante Manansala denied the accusations and posited that his wife was only trying to get
back at him for not providing financial support to his children with her. Dante did not deny that Jennifer
was with him from October 31 up to November 14, 1991 but he did not do anything to her. Dante also
alleged that Teresita was a very violent person and that Jennifer would often show him marks caused by
Teresita. Despite this, the trial court found Dante Manansala guilty of having raped his daughter in the taho
factory in Tondo Manila on November 1, 1991. Moreover, although the trial court notes that the rape
incidents did occur from November 2- November 8, the charges necessarily have to be dismissed for lack
of jurisdiction.
Issue: W/N the trial court erred in convicting Dante Manansala?
Held:
YES. The discrepancies in the testimonies of Jennifer combined with that of her mother Teresita
necessarily calls for the reversal of judgment. Assuming that the rape incident did occur in Tondo on
November 1, 1991, it is illogical that Jennifer would join her father to go to Tarlac after such a traumatic
experience. It is also important to note that the lacerations in Jennifer’s private area are not sufficient or
indicative of forceful rape in consecutive days. Trial court decision is REVERSED and Dante Manansala is
ACQUITTED.