PP vs.

Ramirez
G.R. No. L-10951

October 23, 1958

FACTS:
During a religious service, Appellant Ramirez situate himself behind deceased Cristanto
Manalo, a short fellow with short and paralyzed arms (sinkol) and fingers, and, without any ado,
suddenly stab Manalo on the back with a double-edged dagger nine inches long. Manalo staggered
on his left and fell.
Jose Evangelista, another spectator, approached appellant with the intention of separating
him from Manalo and prevent further harm, appellant stabbed Evangelista twice on the chest,
inflicting two wounds thereby, whereupon Evangelista ran away chased by appellant. For these two
stab wounds Evangelista was hospitalized for nine days.
Appellant admits having inflicted the stab wound which caused the death of the deceased,
but pleads self-defense. Appellant in his brief stresses the fact that, by reason of the failure of the
prosecution to prove any motive, thus affecting the credibility of its witnesses, he is entitled to an
acquittal, considering, besides, that he merely acted in self-defense.
ISSUE:
Whether or not motive should be proven in this case.
RULING:
NO. The question of motive is very important in cases where there is doubt as to whether the
defendant is or is not the person who committed the act, but when there is no doubt, as in the case
at bar, that the defendant was the one who caused the death of the deceased, it is not so important
to know the exact reason for the deed.
There being an admission by appellant himself that he was the one who stabbed the
deceased, there was no need for the prosecution to inquire into his motive.

PP vs. Sampior

G.R. No. 117691. March 1, 2000

FACTS:

On March 5, 1994, private complainant, the eldest of appellants nine children, was
raped twice by her own father.
Two separate complaints of rape were filed against the appellant. On arraignment,
appellant, assisted by the public attorney, pleaded "Not guilty" to each charge. The two cases
were then jointly tried. The prosecution presented three witnesses, including the complainant.
One of the witnesses, Dr. Toledo, testified that he did not find any laceration of the complainants
hymen nor any contusions or other injuries in her body. However, he pointed out there are some
hymens that are "thick, elastic and flexible,"[5] and thus, he could not discount the possibility that
a rape victims hymen would remain intact an exhibit no lacerations.
Appellant did not take the witness stand. He chose not to present his side of the case.
Instead, the defense presented the private complainant as a hostile witness to testify that there
was no full penile penetration of her womanhood. Appellant contends that he should have been
convicted of frustrated rape only, and that the sentence on him should be reduced,
correspondingly, pointing to the old ruling in People v. Erinia,[19] where the Court held that there
being no conclusive evidence of the penetration of the genital organ of the offended party, the
defendant was entitled to the benefit of the doubt, and could only be found guilty of frustrated
rape.
ISSUE:
Whether or not appellant is guilty only of frustrated rape.
RULING:
NO. Later cases have overruled Erinia. We now hold that the crime of frustrated rape is
non-existent in our criminal law.[20] In abandoning Erinia, the Court declared that the merest
touch of the male organ upon the labia of the pudendum, no matter how slight, consummates
the rape.