Case Title: PEOPLE v. MATEO, G.R. No. 147678-87, July 7, 2004, 433 SCRA 640 Doctrine

CASE TITLE: PEOPLE v. MATEO, G.R. No.
147678-87, July 7, 2004, 433 SCRA 640

DOCTRINE:
While the Fundamental Law requires a mandatory review by the Supreme Court of cases
where the penalty imposed is reclusion perpetua, life imprisonment, or death, nowhere,
however, has it proscribed an intermediate review. If only to ensure utmost circumspection
before the penalty of death, reclusion perpetua or life imprisonment is imposed, the Court now
deems it wise and compelling to provide in these cases a review by the Court of Appeals before
the case is elevated to the Supreme Court.
Where life and liberty are at stake, all possible avenues to determine his guilt or
innocence must be accorded an accused, and no care in the evaluation of the facts can ever be
overdone. A prior determination by the Court of Appeals on, particularly, the factual issues,
would minimize the possibility of an error of judgment
FACTS
Ten (10) informations, one for each count of rape, alleged committed on ten (10)
different dates were filed against Efren Mateo. According to Imelda Mateo, the complainant
and the appellant’s stepdaughter, each time the ten rape incidents occurred, her mother was
away.
She stated that each of the ten rape incidents were committed in invariably the same
fashion – inside their house, during the night, and each time, she would try to ward off his
advances by kicking him to no avail. These incidents occurred in the presence of her three
sleeping siblings who failed to wake up despite her struggle. She recalled that in all ten
instances, appellant had covered her mouth with a handkerchief to prevent her from shouting.
Subsequently, however, she changed her statement to say that the appellant had only covered
her mouth with his hands. Still much later, Imelda testified that he had not covered her mouth
at all.
Appellant denied all charges against him and stated that the charges was the malicious
“retribution” of his stepdaughter, after he forbade her from seeing Pikong Navarro because
Imelda was seen in two instances, by her brother and by her friend, respectively, engaging in
sexual intercourse with Pikong inside their house. Both her brother and her friend testified in
court.
Rosemarie, the mother of the complainant, testified in defense of her common-law
husband, asserting that she had not at any time, spent any night outside the house.
The appellant was found guilty beyond reasonable doubt of ten (10) counts of rape. The
Court has deemed it sufficient to convict the accused for rape solely on the basis of the
testimony of the victim, finding justification on the fact that, generally, the victim would be the
sole witness to the incident and the shy and demure character of the typical Filipina would
preclude her from fabricating that crime.
The Solicitor General assailed the factual findings of the trial court and recommended an
acquittal of the appellant.
ISSUE
Whether or not the case should be directly forwarded to the Supreme Court by virtue of
express provision in the Constitution regarding automatic appeal where the penalty imposed is
reclusion perpetua, life imprisonment or death.
RULING
Up until now, the Supreme Court has assumed the direct appellate review over all
criminal cases in which the penalty imposed is death, reclusion perpetua or life imprisonment.
The practice finds justification in the 1987 Constitution—
Article VIII, Section 5. The Supreme Court shall have the following powers:
“(2) Review, revise, reverse, modify, or affirm on appeal or certiorari, as the law or the
Rules of Court may provide, final judgments and orders of lower courts in:
xxx xxx xxx
(d) All criminal cases in which the penalty imposed is reclusion perpetua or
higher.”
It must be stressed, however, that the constitutional provision is not preclusive in

character, and it does not necessarily prevent the Court, in the exercise of its rule-making
power, from adding an intermediate appeal or review in favor of the accused.
While the Fundamental Law requires a mandatory review by the Supreme Court of cases
where the penalty imposed is reclusion perpetua, life imprisonment, or death, nowhere,
however, has it proscribed an intermediate review. If only to ensure utmost circumspection
before the penalty of death, reclusion perpetua or life imprisonment is imposed, the Court now
deems it wise and compelling to provide in these cases a review by the Court of Appeals before
the case is elevated to the Supreme Court. Where life and liberty are at stake, all possible
avenues to determine his guilt or innocence must be accorded an accused, and no care in the
evaluation of the facts can ever be overdone. A prior determination by the Court of Appeals on,
particularly, the factual issues, would minimize the possibility of an error of judgment.
Procedural matters, first and foremost, fall more squarely within the rule-making
prerogative of the Supreme Court than the law-making power of Congress. The rule here
announced additionally allowing an intermediate review by the Court of Appeals, a subordinate
appellate court, before the case is elevated to the Supreme Court on automatic review, is such
a procedural matter.
The case was REMANDED, and all pertinent records thereof were ordered to be
FORWARDED, to the Court of Appeals for appropriate action.
__________________________
By: Dana Recah Feliz P. Yee

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CASE TITLE: PEOPLE v. MATEO, G.R. No.

147678-87, July 7, 2004, 433 SCRA 640

It must be stressed, however, that the constitutional provision is not preclusive in

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