People v. Mateo

Summary

This landmark criminal case involved the prosecution of Efren Mateo for ten counts of rape against his stepdaughter. While the Regional Trial Court convicted based on victim testimony, the Supreme Court found significant inconsistencies in the evidence, including contradictory statements about sleeping arrangements, family member locations, and the victim's mother's whereabouts. More importantly, the case established a crucial procedural reform requiring intermediate Court of Appeals review before death penalty, reclusion perpetua, or life imprisonment cases reach the Supreme Court. This reform was based on statistics showing that 71.77% of automatic review cases were either modified or vacated, with only 25.36% of death penalties affirmed. The Court remanded the case to the Court of Appeals, fundamentally changing Philippine criminal appellate procedure to ensure more thorough review of cases involving life and liberty.