G.R. No. 227396 - People vs. Milo Leocadio Labrador

On March 26, 2002, at approximately 3:00 p.m., spouses BBB and CCC instructed their 12-year-old daughter, AAA, along with her two siblings, to collect payment for rice cakes from the accused-appellant Milo Leocadio y Labrador (Milo).
Only AAA failed to return home; the siblings came back but AAA was missing.
Concerned, BBB searched for AAA the entire night but was unsuccessful.

On the following day, BBB and CCC reported AAA's disappearance to the police.
Barangay officials informed BBB that they found AAA's lifeless body in Milo's house.
Upon visiting the crime scene, BBB saw AAA's body underneath a wooden bed, lying flat on her back; her mouth and nose were covered with cloth, and both hands were tied and twisted behind her back.
Autopsy results: Cause of death was asphyxia by suffocation.
Medical examination found hymenal lacerations at the 3 o'clock position and 33 injuries and abrasions on various parts of AAA's body.

Milo was charged with the complex crime of rape with homicide before the Regional Trial Court (RTC), Romblon, Criminal Case No. OD-1498.
The charges included that Milo, by means of force, threats, or intimidation, had carnal knowledge of AAA, a minor, and assaulted her leading to her death.
Milo pleaded not guilty, admitting only to the killing which he claimed was accidental: he alleged that after being abruptly awakened by AAA touching his shoulder, he unconsciously punched her, causing her to hit the wall and fall dead.
Milo denied raping AAA.

The RTC, on April 1, 2013, found sufficient circumstantial evidence proving Milo guilty beyond reasonable doubt of rape with homicide.
The court heavily relied on the autopsy findings and BBB's testimony concerning the circumstances before and after the crime.
Milo was sentenced to reclusion perpetua without parole and ordered to pay civil indemnity and damages to the heirs of AAA.

Milo appealed, challenging the credibility of BBB's testimony and the sufficiency of circumstantial evidence.
Milo reiterated his claim of accidental killing and denied rape.
On September 15, 2015, the CA affirmed the RTC decision, with modifications awarding interest on damages.
The CA highlighted the unbroken chain of circumstantial evidence, including admission of Milo that AAA was in his house and he hit her, medico-legal findings of suffocation and hymenal lacerations, and injuries inconsistent with Milo's claim of a single punch.

Milo filed a petition for review before the Supreme Court.
Both parties did not file supplemental briefs, having exhausted issues in previous pleadings.
The Supreme Court proceeded with the assessment of the facts, evidence, and applicable law.

Whether or not the accused-appellant Milo Leocadio y Labrador is guilty beyond reasonable doubt of the complex crime of rape with homicide involving a minor victim.
Whether the defense of accidental killing invoked by Milo is valid.
Whether the circumstantial evidence presented by the prosecution is sufficient to establish Milo's guilt beyond reasonable doubt.
Proper award of civil and moral damages to the heirs of the victim.