Title
Diega y Pajares vs. Court of Appeals
Case
G.R. No. 173510
Decision Date
Mar 15, 2010
A man is sentenced to reclusion perpetua without parole for rape with homicide, upheld by credible witness testimonies despite his claims of innocence and unlawful arrest.
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Case Digest (G.R. No. 173510)

Facts:

  • The case involves Erpascual Diega y Pajares (appellant) as the accused and the People of the Philippines as the appellee.
  • The incident occurred on March 17, 1995, in San Jose del Monte, Bulacan.
  • The appellant, a stay-in security guard, was accused of the complex crime of rape with homicide against a 13-year-old girl, referred to as "AAA."
  • The Amended Information alleged that the appellant, with lewd intent and through force and intimidation, had carnal knowledge of "AAA" against her will and subsequently killed her.
  • The victim was reported missing by her parents after she did not return home from school.
  • Her body was found the next day, covered with leaves, showing signs of strangulation and multiple wounds.
  • A medico-legal examination confirmed death by asphyxia due to strangulation and traumatic injuries consistent with rape.
  • Witness Juanito Manalo III testified that he encountered the appellant near the victim's body, where the appellant threatened him with a pistol and forced him to touch the victim's body.
  • Other witnesses corroborated Juanito's testimony, noting the appellant's threatening demeanor and absence from his post during the crime.
  • The appellant denied the allegations, claiming he was elsewhere and was falsely accused due to a land dispute with the victim's family.
  • The Regional Trial Court (RTC) found the appellant guilty beyond reasonable doubt and sentenced him to death.
  • The Court of Appeals (CA) affirmed the RTC's decision with modifications regarding civil indemnity.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the appeal lacked merit, affirming the decision of the Court of Appeals.
  • The appellant was found guilty beyond reasonable doubt of the complex crime of rape with homicide.
  • He was sentenced to...(Unlock)

Ratio:

  • The Supreme Court emphasized that a conviction can be based on circumstantial evidence if it forms an unbroken chain leading to a fair and reasonable conclusion pointing to the accused as the perpetrator.
  • Circumstantial evidence included the appellant's employment at the crime scene, his lewd behavior towards the victim, his absence from his post during the crime, and threats made against Juanito, a witness.
  • The Court noted that the prosecution's evidenc...continue reading

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