Case Digest (G.R. No. 135382)
Facts:
In The People of the Philippines v. Pablito Andan y Hernandez @ Bobby (G.R. No. 116437, March 3, 1997), the accused-appellant was charged with rape with homicide for the brutal killing of AAA, a 20-year-old college student, on February 19, 1994 in the municipality of xxx, province of xxx. AAA left her home for her dormitory, carrying school uniforms and over ₱2,000 in cash. While walking by the subdivision, Andan invited her into his vacant house under the pretext of taking his grandmother’s blood pressure. Inside, he struck her, raped her by force, then dragged her unconscious body to an old toilet. After dark, he stood on a bench, hurled her over a six-foot fence, and, upon hearing her moans, repeatedly struck her with a concrete hollow block until she died. Her stripped body was discovered the next morning. A forensic autopsy revealed multiple abrasions, contusions, facial fractures and cerebral contusions; a subsequent NBI re-autopsy showed fresh lacerations of the hymen witCase Digest (G.R. No. 135382)
Facts:
- Crime and Commission
- On February 19, 1994 at about 4:00 P.M. in xxx, Bulacan, accused-appellant Pablito Andan y Hernandez alias “Bobby” lured AAA into his house under the pretext of taking her grandmother’s blood pressure.
- Once inside and alone, he punched her in the abdomen, raped her by violence and intimidation, rendered her unconscious and carried her to an old toilet.
- At nightfall, he dragged her unconscious body over a six-foot fence, assaulted her with a concrete block until silence ensued, and abandoned her naked corpse in a vacant lot.
- Discovery and Physical Evidence
- On February 20, 1994 at 11:00 A.M., AAA’s body was found nude from the chest down; nearby lay her brassiere, T-shirt, panty and sanitary napkin.
- Autopsy (Bulacan Provincial Hospital, Feb. 22) revealed multiple abrasions, contusions, lacerations and facial fractures; cause of death was cardiorespiratory arrest due to cerebral contusions from traumatic facial injuries.
- A broken concrete block stained with blood, AAA’s denim pants and shoes were recovered at the scene. At appellant’s house police found bloodstains on the pigpen wall and, surrendered by a relative, pornographic pictures and stained clothing allegedly belonging to appellant.
- Arrest, Confessions, Alibi and Trial
- Appellant was located at his parents’ home on February 24, 1994 and brought to police headquarters un-Mirandized; he first blamed neighbors, then pointed out AAA’s bags under a flower pot. These admissions and recovered bags were recorded.
- On February 25 mayor privately met appellant, who spontaneously confessed in the mayor’s office (videotaped before media), then repeated and reenacted to various TV and print reporters over succeeding days.
- At arraignment appellant pled not guilty, claiming alibi: he was at a family birthday party in xxx and at his parents’ house from afternoon to arrest. Trial court convicted him of rape with homicide, sentenced him to death, and awarded civil indemnity, burial expenses and moral damages.
Issues:
- Whether the trial court erred in admitting testimonies on appellant’s custodial and extrajudicial confessions without counsel, in violation of Section 12(1) and (3), Article III of the Constitution.
- Whether there was sufficient medical evidence to prove rape.
- Whether the evidence as a whole established appellant’s guilt beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)