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    People v. Magpayo

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    shookt panboi
    The defendant Magpayo was accused of four crimes against young girls under 12: rape, robbery, robbery with holdup, and forcible abduction with rape. The trial court jointly tried the cases and found Magpayo guilty. Magpayo appealed, claiming the trial court wrongly applied the doctrine of res inter alios acta by considering evidence from the different cases. However, the Supreme Court held that the trial court did not err because the evidence showed Magpayo had a common scheme or plan of accusing young girls of crimes to lure them to isolated places to rape or rob them. The similarities in Magpayo's modus operandi made the evidence from the different cases admissible.

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    People v. Magpayo

    Uploaded by

    shookt panboi
    102 views1 page
    The defendant Magpayo was accused of four crimes against young girls under 12: rape, robbery, robbery with holdup, and forcible abduction with rape. The trial court jointly tried the cases and found Magpayo guilty. Magpayo appealed, claiming the trial court wrongly applied the doctrine of res inter alios acta by considering evidence from the different cases. However, the Supreme Court held that the trial court did not err because the evidence showed Magpayo had a common scheme or plan of accusing young girls of crimes to lure them to isolated places to rape or rob them. The similarities in Magpayo's modus operandi made the evidence from the different cases admissible.

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    The defendant Magpayo was accused of four crimes against young girls under 12: rape, robbery, robbery with holdup, and forcible abduction with rape. The trial court jointly tried the cases and found Magpayo guilty. Magpayo appealed, claiming the trial court wrongly applied the doctrine of res inter alios acta by considering evidence from the different cases. However, the Supreme Court held that the trial court did not err because the evidence showed Magpayo had a common scheme or plan of accusing young girls of crimes to lure them to isolated places to rape or rob them. The similarities in Magpayo's modus operandi made the evidence from the different cases admissible.

    Copyright:

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

    People v. Magpayo

    Uploaded by

    shookt panboi
    The defendant Magpayo was accused of four crimes against young girls under 12: rape, robbery, robbery with holdup, and forcible abduction with rape. The trial court jointly tried the cases and found Magpayo guilty. Magpayo appealed, claiming the trial court wrongly applied the doctrine of res inter alios acta by considering evidence from the different cases. However, the Supreme Court held that the trial court did not err because the evidence showed Magpayo had a common scheme or plan of accusing young girls of crimes to lure them to isolated places to rape or rob them. The similarities in Magpayo's modus operandi made the evidence from the different cases admissible.

    Copyright:

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

    People v.

    Magpayo
    G.R. No. Nos. 92961-64; 1 Sep 1993
    THIRD DIVISION; BIDIN, J

    Facts: Magpayo here was accused in 4 cases (rape, robbery, robbery with holdup, and forcible
    abduction with rape). It can be observed from these cases that the victims are usually young girls
    under the age of 12. What Magpayo would do is that he would accuse these minor of a crime
    then he would bring them to an isolated place them he would rape or rob them. The trial court
    jointly tried these cases and found Magpayo guilty of all of them.
    Magpayo assails the trial court’s application of the doctrine of res inter alios acta (Sec. 35, Rule
    130 of the Revised Rules of Evidence) allegedly because the similarity of the acts involved (i.e.,
    molestation) was not sufficiently established.

    Issue: Whether the Trial Court erred in the application of Section 35 of rule 130 of the Rules of
    Evidence.

    Held: No.
    Rule under Section 35, Rule 130:
    Evidence which shows that the accused in a criminal case has committed a crime wholly
    independent of the offense for which he is on trial is not admissible.

    Exception:
    When such evidence tends directly to establish the particular crime, and it is usually competent
    to prove 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.

    In this case, the evidence introduced in the Forcible Abduction with Rape was not introduced as
    evidence of similar acts to prove that the accused also committed a similar act in the other rape
    and robbery.

    The evidence was not offered and admitted to prove the other but only to show the plan,
    scheme or modus operandi of the offender.

    As observed by the Trial Court, the modus operandi of the offender is that of approaching young
    girls of not more than twelve years of age, and taking advantage of their innocence, imputed to
    them the commission of a crime and brought them to an isolated place where the offenses
    charged were committed.

    Thus, as provided under section 35 of rule 130, evidence that one did or did not do a certain
    thing at one time may be received to prove a specific intent or knowledge, identity, plan, system,
    scheme, habit, custom or usage and the like.

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