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PEOPLE vs Genaro Biong

PEOPLE OF THE PHILIPPINES, appellee, vs. GENARO BIONG, appellant.

G.R. No. 144445-47 | 2003-04-30

D E C I S I O N

PANGANIBAN, J.:

Just as the prosecution is still required to present evidence to prove the guilt of the accused beyond reasonable doubt despite a guilty plea in a capital offense, so must the government submit independent evidence to prove beyond reasonable doubt all the elements -- including the qualifying circumstances -- of the crime of rape despite the appellant's admissions during his testimony or during pretrial.

The Case

For automatic review before this Court is the August 17, 2000 Decision[1] of the Regional Trial Court (RTC) of Calamba, Laguna (Branch 36) in Criminal Case Nos. 6586-99-C, 6587-99-C and...