G.R. No. 78813 -14 November 8, 1993
People of the Philippines, plaintiff-appellee, vs. Farhad Hatani y Abolhassan, accused-appellant.

FACTS

Accused-appellant Farhad Hatani was convicted by the Regional Trial Court of Quezon City in two separate cases. In Criminal Case No. Q-11867, he was found guilty of illegal practice of medicine under R.A. No. 2382 (Medical Act of 1959). In Criminal Case No. Q-11868, he was found guilty of rape under Article 335 of the Revised Penal Code. The charges stemmed from incidents on July 6, 1979. Agustina Borja sought help for her sick 16-year-old daughter, Precila. Appellant, introduced as a medical doctor by his wife Marita, examined Precila at her home, administered injections causing her to become dizzy and fall asleep, and diagnosed her as a drug addict. Precila was later brought to appellant’s house for further observation. There, after being injected again, she awoke naked, in pain, and found appellant fondling her private parts. He punched her, pressed a pillow on her face, and injected her again. She awoke a second time to find appellant naked in bed with her, fondling her, and she saw blood stains on her hand. The next morning, Agustina found Precila and appellant both naked and asleep in bed. Appellant had also diagnosed and treated Precila’s sister, Wilma, as a drug addict. Josefina, another sister and a nurse, intervened and stopped appellant from injecting Wilma. Precila and Wilma were examined, with Precila’s medico-legal report showing deep, healing hymenal lacerations and needle marks. A raid on appellant’s residence on July 15, 1979, led to the seizure of assorted drugs (dalmane, valium, mogadon), prescription pads in the name of Dr. Jesus Yap (with handwriting identified as appellant’s), and medical instruments. The Professional Regulation Commission certified appellant was not a registered physician. Appellant denied the charges, claiming Precila stayed at his house to confide personal problems, that he slept on the floor, and that the drugs seized during the raid were planted. The trial court convicted him based on the evidence.

ISSUE

The primary issues were whether the prosecution proved beyond reasonable doubt that appellant committed the illegal practice of medicine and the crime of rape.

RULING

The Supreme Court affirmed the trial court’s decisions in toto. On the charge of illegal practice of medicine, the Court found overwhelming evidence, including the testimonies of the victims and their relatives, medico-legal reports showing needle marks, seized drugs and medical instruments, prescription pads with appellant’s handwriting, and certification that he was not a licensed physician. The Court rejected appellant’s claim that the evidence was planted, noting the existence of a search warrant and the admissibility of the seized items. The Court also held that proof of payment was not necessary for conviction under the law. On the charge of rape, the Court upheld the conviction based on circumstantial evidence, which included: (1) the medico-legal report confirming Precila was in a non-virgin state with deep, healing lacerations; (2) the multiple needle puncture marks indicating she was drugged; (3) Agustina’s testimony finding her daughter and appellant naked together; and (4) Precila’s own account of the sexual assault. The Court found these circumstances formed an unbroken chain leading to the conclusion that appellant raped Precila. The Court also rejected appellant’s claim that the judgment was erroneous because the judge who wrote the decision did not hear the evidence, stating that where the evidence on record is sufficient, this does not render the judgment erroneous.