People vs.

de Leon Facts: Accused supposedly raped his daughter in front of the latters own 2 year old daughter. Accused flatly denied the charge. He alleged that the prosecution evidence had not proven his guilt beyond reasonable doubt because: (1) the evidence for the prosecution which consisted of the victims sole testimony is insufficient; (2) this testimony is inconsistent; and (3) the other pieces of vital evidence, i.e., the knife and the victims torn clothes, were not presented to substantiate the victims testimony. Issue: WON the sole testimony of the victim is sufficient to establish the guilt of Edgardo de Leon. Held: Yes. The sole testimony of the victim sufficiently establishes the guilt of accused-appellant. Amelia de Leon testified naturally, spontaneously and positively. Accused-appellants claim that the charge against him was merely trumped up by Amelia cannot be believed. No woman, especially a daughter, would subject herself and her family to the humiliation of a public trial and send her father to jail for the rest of his life if her accusation were not true. Since the rape was committed with the use of a knife, a deadly weapon, the crime is therefore punishable by reclusion perpetua to death. People vs. Mumar Facts: Mumar et.al (ranch caretaker and cowboys) were accused for having shot Villaver (laborer of the same cattle corporation as Mumars) from the back thereby resulting to the latters instantaneous death. Accused denied the charge. They alleged that the lower court erred in holding the prosecutions evidence to be sufficient to establishing the aggravating circumstance of abuse of superior strength. Issue: WON the failure to submit in evidence the gun used in the killing results to the insufficiency of establishing the guilt of the accused. Held: The failure to submit in evidence the gun used in the killing was not a fatal omission because the People's evidence had established that the deceased died as a result of a gunshot. One of the witnesses for the prosecution testified that the victim died of gunshot wounds which was caused by a shotgun.-- a gun somewhat similar to the one held by one of the accused. Furthermore, well-settled is the rule that paraffin tests are inconclusive.

Finally, during the trial it was proven that appellants enjoyed not only numerical superiority over the victim and his son, but also of arms consisting of a shotgun, a revolver and a bolo, while Arsenio (deceased) and Vincent (son) Villaver were unarmed. The trial court was therefore correct in appreciating abuse of superior strength as the qualifying circumstance that raised the killing of Arsenio Villaver to murder.