Case Digest (G.R. No. 136253)
Facts:
This is People of the Philippines v. Clemente John Lugod, G.R. No. 136253, February 21, 2001, Supreme Court En Banc, Gonzaga‑Reyes, J., writing for the Court. The accused‑appellant is Clemente John Lugod (also referred to as “Honasan”); the plaintiff‑appellee is the People of the Philippines.On October 10, 1997 an Information charged Lugod with rape with homicide under Section 11 of Republic Act No. 7659, alleging that on or about September 16, 1997 in Cavinti, Laguna he had carnal knowledge of eight‑year‑old Nairube J. Ramos by force and intimidation and, to hide the crime, dumped her body which resulted in death. At arraignment Lugod pleaded not guilty and trial followed before the Regional Trial Court (RTC), Branch 28, Santa Cruz, Laguna.
The prosecution presented multiple witnesses: the medico‑legal officer who found an 8‑cm vaginal laceration and opined cause of death as hypovolemic shock secondary to laceration; barrio officials, neighbors and townspeople who placed Lugod at or near Villa Anastacia and the victim’s house on the night of September 15–16, 1997 and who identified a black T‑shirt and a pair of ordinary rubber slippers they said Lugod had worn; members of the police who arrested Lugod and testified that he allegedly admitted raping and killing the child and pointed out the place where the body was hidden; and the victim’s parents who described the disappearance and the discovery of the panty and other items. The vice‑mayor testified that he visited Lugod in the cell and recounted an ambiguous exchange; he did not record a categorical confession. The medico‑legal and searching testimony established decomposition and location of the body three days before the medico‑legal exam.
On October 8, 1998 the RTC found Lugod guilty beyond reasonable doubt of rape with homicide and sentenced him to death, ordered indemnity and actual damages, and assessed costs. Because the RTC imposed the death penalty, the case was brought to the Supreme Court on automatic review. In his appellate brief Lugod chiefly argued that (1) the conviction rested on circumstantial evidence that did not prove guilt beyond reasonable doubt and (2) the alleged confession was inadmissible because it was elicited in violat...(Subscriber-Only)
Issues:
- Was Lugod’s alleged confession and his subsequent pointing out of the body admissible evidence, or were they obtained in violation of his rights under Article III, Section 12 of the 1987 Constitution?
- Was the circumstantial evidence presented sufficient to prove Lugod guilty beyond reasonable doubt...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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