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People V Ritter

1. The Supreme Court reversed the trial court's conviction of Ritter for rape with homicide. While Ritter's actions with the minors were offensive, the evidence did not prove beyond reasonable doubt that he was criminally liable for Rosario's death. 2. However, Ritter could still face civil liability. An acquittal in a criminal case requires proof beyond reasonable doubt, but civil liability only requires a preponderance of evidence. Ritter's actions towards the minors, while not the basis for the criminal charges, could still form the basis for civil damages. 3. The different standards of proof in criminal vs civil cases is why an acquittal does not necessarily exempt someone from civil

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133 views2 pages

People V Ritter

1. The Supreme Court reversed the trial court's conviction of Ritter for rape with homicide. While Ritter's actions with the minors were offensive, the evidence did not prove beyond reasonable doubt that he was criminally liable for Rosario's death. 2. However, Ritter could still face civil liability. An acquittal in a criminal case requires proof beyond reasonable doubt, but civil liability only requires a preponderance of evidence. Ritter's actions towards the minors, while not the basis for the criminal charges, could still form the basis for civil damages. 3. The different standards of proof in criminal vs civil cases is why an acquittal does not necessarily exempt someone from civil

Uploaded by

Princess Joan Inguito
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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PEOPLE vs.

RITTER
G.R. No. 88582 - March 5, 1991
People of the Philippines, plaintiff-appellee,
versus
Heinrich S. Hitter, accused-appellant
Topics: a. Duty to render judgment and b. Human Relations

Facts:
On October 10, 1986 about midnight, accused Heinrich Hitter, an Austrian national brought
Rosario Baluyot and Jessie Ramirez on a hotel in Olongapo City. Heinrich masturbated
Ramirez and fingered Baluyot. Ramirez was paid an amount of Php 200.00 and Php 300.00 to
Baluyot. The following morning, Rosario Baluyot told Jessie Ramirez that the accused has
inserted something on her vagina. Sometime after the incident, Rosario told Ramirez that she
had already removed the object on her vagina however Ramirez claimed that on the evening of
the same date he saw Rosario complaining pain of her vagina and asked her again about the
object which Rosario said that it was not still removed.On May 14, 1987, Gaspar Alcantara saw
Rosario with a bloody skirt, unconcious and foul smelling. He then brought Rosario at the
hospital and a physician conducted a check up on her and found out that there was a foreign
object inside her body. The physician tried to remove the object but failed to do so because the
foreign object was deeply embedded on her vaginal cover and was already covered with tissue.
She was scheduled for an operation, but not so long, was pronounced dead due to infections
caused by Perotinitis and Septicimia.

A case of Rape with Homicide was filed against Heinrich Ritter. RTC found him guilty beyond
reasonable doubt citing the provision of Art. 4 of the Revised Penal Code “He who is the cause
of the cause is the cause of the evil caused.” However, Supreme Court reversed the decision of
the RTC and acquitted Ritter.

Issue:
1. Whether or not Ritter should be liable for the case of rape and homicide filed against
him?
2. Whether or not the acquittal of Ritter in the criminal case also exempt him from a civil
liability?

Ruling:

1. The trial court convicted the accused citing the rationale of Article 4 of the RPC: He who
is the cause of the cause is the cause of the evil caused. The basic principle in every
criminal prosecution is that accusation is not synonymous with guilt. The accused is
presumed innocent until the contrary is proved by the prosecution. If the prosecution
fails, it fails utterly, even if the defense is weak or, indeed, even if there is no defense at
all. The defendant faces the full panoply of state authority with all "The People of the
Philippines" arrayed against him. In a manner of speaking, he goes to bat with all the
bases loaded. The odds are heavily against him. It is important, therefore, to equalize the
positions of the prosecution and the defense by presuming the innocence of the accused
until the state is able to refute the presumption by proof of guilt beyond reasonable doubt.
The established facts do not entirely rule out the possibility that the appellant could have
inserted a foreign object inside Rosario's vagina. This object may have caused her
death. It is possible that the appellant could be the guilty person. However, the Court
cannot base an affirmance of conviction upon mere possibilities. Suspicions and
possibilities are not evidence and therefore should not be taken against the accused.
2. the Court can not ignore the acts of the appellant on the children, Jessie Ramirez and
Rosario Baluyot in October, 1986 at the MGM Hotel. Inspite of his flat denials, we are
convinced that he comes to this country not to look at historical sights, enrich his intellect
or indulge in legitimate pleasures but in order to satisfy the urgings of a sick mind. Ritter
was prosecuted for rape with homicide and not pedophilia, assuming this is a crime by
itself. Pedophilia is clearly a behavior offensive to public morals and violative of the
declared policy of the state to promote and protect the physical, moral, spiritual and
social well-being of our youth. Furthermore, it does not necessarily follow that the
appellant is also free from civil liability which is impliedly instituted with the criminal
action. The well-settled doctrine is that a person while not criminally liable, may still be
civilly liable. . . . While the guilt of the accused in a criminal prosecution must be
established beyond reasonable doubt, only a preponderance of evidence is required in a
civil action for damages. (Article 29, Civil Code). The reason for the provisions of Article
29 of the Civil Code, which provides that the acquittal of the accused on the ground that
his guilt has not been proved beyond reasonable doubt does not necessarily exempt him
from civil liability for the same act or omission, has been explained by the Code
Commission.

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