Case Digest (G.R. No. 130612)
Facts:
In the afternoon of October 17, 1996, the lifeless body of six-year-old Jennifer Domantay was discovered in a bamboo grove in Guilig, Malasiqui, Pangasinan. The victim, missing since lunch, bore thirty-eight stab wounds on her back. A local health physician, Dr. Ma. Fe Leticia Macaranas, conducted a preliminary post-mortem and noted multiple organ failure due to hypovolemic shock; she found no visible genital lacerations but recommended an NBI autopsy for possible lascivious acts. Police officers later arrested Bernardino Domantay @ “Junior Otot”, a cousin of the victim’s grandfather, at the Malasiqui public market on the evening of October 17. In police custody, SPO1 Antonio Espinoza took his oral confession to the killing and claimed the bayonet was hidden with the Casingals in Bayambang, where it was seized the next day. On October 25, 1996, NBI medico-legal expert Dr. Ronald Bandonill’s autopsy revealed a complete right-side hymenal laceration and signs of inflammation, promCase Digest (G.R. No. 130612)
Facts:
- Circumstances of the Crime
- On October 17, 1996 at about 4:00 PM, the body of six-year-old Jennifer Domantay was found in a bamboo grove in Guilig, Malasiqui, Pangasinan, bearing 38 stab wounds on her back.
- Dr. Ma. Fe Leticia Macaranas conducted an initial post-mortem showing death by hypovolemic shock and multiple organ failure; no clear signs of genital laceration though the vaginal canal admitted a little finger with minimal resistance.
- Investigation and Arrest
- Police officers arrested accused-appellant Bernardino “Junior Otot” Domantay at Malasiqui public market that evening; under questioning by SPO1 Espinoza he allegedly confessed to the killing and disclosed he handed the bayonet to relatives in Bayambang.
- On October 18, police recovered the bayonet from the Casingals’ tricycle; a receipt was executed for the confiscation.
- Autopsy and Amended Information
- On October 25, 1996, NBI medico-legal expert Dr. Ronald Bandonill performed an autopsy on the embalmed body, finding complete laceration of the right side of the hymen and signs of inflammation, prompting amendment of the complaint from murder to rape with homicide.
- The amended information charged Domantay with armed rape of a six-year-old Jennifer Domantay against her will, and on the same occasion stabbing her multiple times resulting in death.
- Trial Proceedings
- Prosecution presented seven witnesses: relatives Edward, Jiezl, Lorenzo Domantay; tricycle driver Joselito Mejia; investigator SPO1 Espinoza; radio reporter Celso Manuel; and Dr. Bandonill—each testifying to sightings, confessions, or forensic findings.
- Defense called the accused, who denied all allegations, offered an alibi of bathing pigs and buying liquor, and contested both the police and media-obtained confessions.
- Lower Court Decision and Sentence
- The Regional Trial Court (Dagupan, Br. 57) found Domantay guilty beyond reasonable doubt of rape with homicide (RPC Arts. 335 & 248 as amended by RA 7659) and sentenced him to death by lethal injection.
- He was ordered to indemnify the victim’s heirs ₱480,000 and pay costs.
Issues:
- Whether the extrajudicial confessions to SPO1 Espinoza and to radio reporter Celso Manuel were admissible.
- Whether the prosecution proved the elements of rape with homicide beyond reasonable doubt.
- Whether the evidence supported conviction for homicide and/or rape.
- Whether the awards for actual, moral, exemplary damages, and indemnity were proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)