G.R. No. 84698 - Philippine School of Business Administration vs. Court of Appeals

Murder under Criminal Case No. 2162-M-2000 for the death of Jennifer Patawaran-Rosal.
Rape under Criminal Case No. 2308-M-2000 for the rape of AAA, a 19-year-old woman.

Both charges arose from the same incident on June 6, 2000, in San Rafael, Bulacan.

On June 6, 2000, AAA and Jennifer were walking along rice paddies to apply for work.
Appellant, armed with an ice pick and lead pipe, waylaid and forcibly took them to a grassy area behind a concrete wall.
Appellant struck AAA on the head with the lead pipe, causing her to fall; he then attacked Jennifer similarly and stabbed her multiple times.
Jennifer was covered with grass and left to die; AAA was further struck, stabbed on the face, and raped by appellant while defenseless.
AAA lost consciousness, regained it during heavy rain, crawled to her grandfather’s farm, and was brought to the hospital.
She learned from hospital stay that Jennifer had died.

AAA testified recounting the attack, the rape, and identifying appellant as her attacker.
BBB, AAA’s grandfather, found AAA in a distressed state and helped her.
CCC, a neighbor, accompanied barangay officials in finding Jennifer’s dead body covered in grass.
Dr. Ivan Viray conducted the autopsy on Jennifer’s body, confirming death due to stab wounds and detailed injuries indicating violent attack.

Appellant denied the charges, claiming he was home cooking dinner with family at the time.
He admitted an altercation at home on the same night unrelated to the attacks.
Appellant’s nephew testified that AAA and Jennifer had slept at appellant’s house the night before and left in the early morning; both left separately from appellant who went to have his scythe repaired.

The RTC found appellant guilty beyond reasonable doubt of both murder and rape.
Sentence of reclusion perpetua was imposed with monetary awards for civil indemnity, moral and exemplary damages.

Affirmed the conviction but modified exemplary damages from P30,000 to P25,000 each.

Whether the trial court erred in giving credence to AAA’s allegedly inconsistent and incredible testimony.
Whether the prosecution failed to prove appellant’s guilt beyond reasonable doubt for the murder of Jennifer and rape of AAA.
Whether the qualifying circumstance of abuse of superior strength was properly appreciated.
Whether the trial court erred in imposing separate convictions for murder and rape rather than a single conviction for a special complex crime.
Whether the award of exemplary damages was proper and sufficiently supported.