Case Digest (G.R. No. 227396)
Case Digest (G.R. No. 227396)
Facts:
People of the Philippines v. Milo Leocadio y Labrador, G.R. No. 227396, February 22, 2023, Supreme Court Second Division, Lopez, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the accused-appellant is Milo Leocadio y Labrador.On March 26, 2002, spouses BBB227396 and CCC227396 instructed their 12‑year‑old daughter, AAA227396, to collect payment for rice cakes from their neighbor, Milo. AAA227396 and her siblings left but only the siblings returned; AAA227396 was missing. The following day, barangay officials informed BBB227396 that AAA227396’s lifeless body had been found in Milo’s house. At the scene, the victim was discovered underneath Milo’s wooden bed, face covered with a cloth, both hands tied and twisted behind her back; the autopsy attributed death to asphyxia by suffocation and recorded hymenal lacerations at the 3 o’clock position and 33 injuries and abrasions across her body.
Milo was charged before the Regional Trial Court (RTC) of Romblon in Criminal Case No. OD‑1498 with the complex crime of rape with homicide. He pleaded not guilty, admitting the killing but asserting it was accidental and denying any sexual assault. In a Decision dated April 1, 2013, the RTC found Milo guilty beyond reasonable doubt of rape with homicide and sentenced him to reclusion perpetua and ordered civil and moral/exemplary/temperate damages.
Milo appealed to the Court of Appeals (CA) via CA‑G.R. CR‑HC No. 06148, arguing the testimony of the victim’s mother was incredible, that circumstantial evidence was insufficient, and reiterating accidental killing and denial of rape. In its September 15, 2015 Decision the CA affirmed the RTC’s conviction, finding the circumstantial evidence formed an unbroken chain tying Milo to the crime, and modified the monetary awards to carry 6% interest per annum. Milo sought recourse to the Supreme Court by way of appeal (see Notice of Appeal dated October 19, 2015); the parties did not file supplemental briefs. The Supreme Court rendered the appealed decision now under review.
Issues:
- Whether the conviction for rape with homicide is supported by evidence beyond reasonable doubt.
- Whether Milo’s defenses of accident, denial and alibi overcome the prosecution’s case.
- What penalty and civil damages, if any, should be imposed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)