G.R. No. 230299 - Penalosa vs. Ocampo, Jr.

On May 18, 1995, at approximately 12:30 P.M. in Barangay Fatima, General Santos City, the victim, Ad Jane Zabala—a 4-year-old daughter of Rosemarie and Alejandro Zabala—was abducted.
In the morning, Rosemarie took Ad Jane to the rural health center for immunization; upon returning home at 11:00 A.M., she discovered that her daughter was missing.
Alejandro Zabala, upon hearing of the disappearance, immediately reported the incident at the Makar Police Station and sought help via local radio announcements.

On May 19, 1995, Alejandro was informed by a neighbor of a found child in a dry creek, leading him to the location where Ad Jane’s body was discovered with hands raised, legs spread, and notable signs of violence.
The victim’s personal items (slippers and a panty bearing distinctive markings) were recovered and identified by the parents, linking the body to Ad Jane.
The autopsy by Dr. Virginia Ramirez revealed advanced decomposition, a lacerated wound at the right inguinal area, evisceration of the intestine, and inflammation with vaginal laceration. However, the doctor admitted that the vaginal injury could have been caused by either an erect penile organ or another hard object.

Several prosecution witnesses—Imelda Arnado, Alma Lawas, Mariano Mahinay, and Rosanna Rentillo—testified that they observed accused-appellant Raymundo Corfin together with the victim:

Arnado noted witnessing the accused conversing with Ad Jane at an abandoned store and later saw them departing together.
Lawas, a nearby resident, corroborated seeing them together while walking in the vicinity of an abandoned store towards RFM.
Mahinay, while en route to his daughter’s home, encountered Corfin carrying a child he recognized as the Zabala’s daughter.
Rentillo observed Corfin walking alone in the direction of her residence after being seen earlier with the victim.

The testimonies established that on the morning of May 18, 1995, the accused was last seen with Ad Jane at the abandoned store and nearby areas where the body was later found.
Despite the absence of direct eyewitness testimony to the crime, a series of circumstantial elements linked Corfin to the incident.

Accused-appellant, who worked as a jeepney conductor, pleaded not guilty and offered a defense based on denial and an alibi:

He admitted to being at the scene around the abandoned store, wearing a yellow sleeveless shirt and short pants as testified by witnesses.
He maintained that after a brief stop, he proceeded to his house in Labangal, where his alibi was corroborated by neighbors.

The trial court, after considering all the circumstantial evidence, found Corfin guilty beyond reasonable doubt on the charge of rape with homicide and imposed upon him the supreme penalty of death.

On automatic review, the appellate court examined the sufficiency of the circumstantial evidence linking the accused to both the homicide and the rape.
While the chain of circumstantial evidence established Corfin’s presence at the scene and connection to the victim’s death, the evidence failed to conclusively prove beyond moral certainty that a rape occurred.
Consequently, the appellate court modified the conviction: the rape charge was not sustained, whereas the homicide charge remained, with adjustments made to the imposed penalty and damages.

Whether the chain of circumstantial evidence satisfies the requisite legal standard to establish the accused’s guilt beyond reasonable doubt.
Whether the multiple independent circumstances collectively point to Corfin as the sole perpetrator of the crime.

Whether the evidence presented, including the autopsy findings and the nature of the vaginal laceration, establishes to a degree of moral certainty that the crime of rape was committed.
Whether the absence of categorical evidence confirming that the laceration was caused by an erect penis precludes a conviction for rape.

Whether the defendant’s alibi and denial, although rebutted by multiple witness testimonies, should be afforded any considerable weight in the face of circumstantial evidence.
Assessment of minor inconsistencies in the testimonies of prosecution witnesses and whether these inconsistencies undermine the overall evidentiary chain.