People of the Philippines ( plaintiff-appellee) plaintiff-appellee) vs. Heinrich S. Ritter (accused-appellant (accused-appellant ) Facts: - On October 10, 1986 midnight, Ritter chose 2 street children namely Jessie Ramirez and Rosario Baluyot, brought them into his room at ! ! "otel in Olonga#o $ity% $ity%
- Ritter as&ed them to ta&e a bath% 'hile Rosario (as ta&ing a bath, Ritter too& out some ob)ects and in #articular, * ob)ects% One o+ the ob)ects is that Ritter #layed (ith it and #laced it on his #alms% t is grayish blue in color and this ob)ect turned out to be the +oreign ob)ect, (hich (as inserted inside the agina o+ Rosario Baluyot% .lso, .lso, Ritter masturbated Ramirez and guide his hand +or him to masturbate on his o(n as they both masturbated at each other% Rosario Rosario Baluyot on the other hand, +inished ta&ing a bath and then she (as instructed by Ritter to get na&ed and )oin (ith them in bed% Ritter started +ingering Rosario% Rosario% - /et morning, Ritter #aid Ramirez (ith the amount o+ 200%00 (hile Rosario Baluyot (as #aid (ith the amount o+ *00%00% .+ter the .merican3 had le+t, Rosario Baluyot told Ramirez that Ritter inserted something into her agina% 4he +ollo(ing day, Ramirez sa( Rosario and as&ed (hether the ob)ect (as already remoed +rom her body and Rosario said yes3% Ramirez claimed that on the same eening, he sa( Rosario com#laining o+ #ain in her agina and (hen he as&ed her, she said that the +oreign ob)ect (as not remoed% - On ay 15, 198, !as#ar .lcantara, (hile garbage scaenging, sa( Rosario being ogled by #eo#le because her s&irt (as bloodied, unconscious and +oul-smelling% "e too& #ity on her condition and brought her to the hos#ital ia )ee#ney% .s .s he reached the in+ormation des& o+ the hos#ital, he (as the one (ho gae the #ersonal in+ormation about Rosario and signed u# as her guardian3 (hile Rosario (as already in the emergency room% "e became a de+ense (itness because he denied that he did not &no( any Rosario Baluyot (hen he brought her to the hos#ital% - On ay 1, 198, a+ter the #hysicians at the hos#ital eamined her, it (as +ound out that there (as a +oreign ob)ect lodged in her aginal canal and she had aginal discharge tinged (ith blood and +oul smelling odor emanating +rom her body% 7r% Barcinal tried to etract the +oreign by using +orce#s but it #roed to be +utile because the said ob)ect (as dee#ly embedded in the aginal canal and (as coered by tissues% Rosarios abdomen (as enlarged, became tender and distended (hich #roed to be sym#toms o+ #eritonitis% 4he o#eration on that day +ailed +ailed because there (as no consent +rom +rom the hos#ital hos#ital director% director% - On ay 19, 198, Rosario undertoo& the o#eration and 7r% Rosete, the hos#ital director, conducted the said o#eration% "e +ound out that her +allo#ian tubes (ere congested (ith #us and so (ith the #eritonieum, and the #elic caity, and #atches o+ #us in the lier, although the gallbladder and &idney a##eared to hae se#ticemia, #oisoning o+ the blood% 4he #eritonitis and se#ticemia (ere traced to hae been caused through in+ection by the +oreign ob)ect, (hich has been lodged in the intra-aginal canal o+ Rosario% 7r% Rosete considered the o#eration success+ul because the ob)ect (as remoed and the #atient (as alie as he le+t Rosario under the custody o+ 7r% $ruz (ho stayed (ith her +or *0 minutes and then le+t% - 4he +ollo(ing day, ay 20, 198, Rosario died and 7r% eo $ruz #ronounced her death at 2:00 to 2:1; in the a+ternoon% - On
Ruling: - 4he $ourt does not agree% .##ellant is ac>uitted%
- 4he #rosecution +ailed to #roe that Rosario (as only 12 years old (hen the incident ha##ened% . doctor testi+ied that the +oreign ob)ect, (hich (as inserted in Rosarios agina, (as di++erent +rom the one that (hich caused her death% 4he eidence (as that Rosario told Jessie the +ollo(ing day a+ter the incident ha##ened that the +oreign ob)ect inserted into her agina (as already remoed% Rosario also told the doctor u#on haing her o#eration that the one (ho #utted the said ob)ect inside o+ her agina (as a /egro3 (hen in +act? the accused (as #roed to be an .ustrian or $aucasian% - .rticle 29 #roides that the ac>uittal o+ the accused on the ground that his guilt has not been #roed beyond reasonable doubt does not necessarily eem#t him +rom ciil liability +or the same act or omission% - 4he $ourt cannot base an a++irmance o+ coniction u#on mere #ossibilities% uirement o+ #roo+, (hich #roduces in an un#re)udiced mind moral certainty or coniction that the accused did commit the o++ense, has not been satis+ied% Doctrine: (NCC 9 !"# RPC $) - n the case o+ Urbano vs. IAC, the $ourt #ointed out that to (it: 4he rule is that the death o+ the ictim must be the direct, natural and logical conse>uence o+ the (ounds in+licted u#on him by the accused% .nd since (e are dealing (ith a criminal coniction, the #roo+ that the accused caused the ictim@s death must conince a rational mind beyond reasonable doubt%3
- n eidence, it is a (ell-entrenched rule that be+ore coniction can be had u#on circumstantial eidence, the circumstances #roed should constitute an unbro&en chain (hich leads to one +air and reasonable conclusion #ointing to the de+endant, to the exclusion of all others, as the author o+ the crime%3
