G.R. No. 120132 - Galay vs. Court of Appeals

The accused, Deorito Porio y Rapsing, was charged with the complex crime of rape with homicide committed on or about June 25, 1990, in Olongapo City, Philippines.
The victim was identified as Riza Cleodoro Flores (referred to by the accused as “Teresa”), an 11-year-old girl, whose death resulted from strangulation.
An Information dated July 10, 1990, filed in the Regional Trial Court, Branch 72, Olongapo City, detailed the commission of the crime with allegations that the accused, with lewd design, unlawfully had carnal knowledge of the victim and, with intent to kill, strangled her during the act.

The prosecution presented several witnesses including Dr. Richard Patilano (the Medico-Legal Officer), Atty. Juanito Atienza, Patrolman Marlon Agno, Corporal Felipe Francia, and Private First Class Roosevelt Menor.
Testimonies from these witnesses established circumstantial evidence such as the discovery of the victim’s body, previous attempts by the accused to commit the crime (as relayed by Barangay Purok Leader Francisco Montes), and the physical condition of the victim.

The Autopsy Report conducted by Dr. Patilano confirmed that the victim died of neurogenic shock and asphyxia by strangulation.
The report documented contusions, lacerations, and genital injuries consistent with a violent sexual assault.
The evidence from the autopsy corroborated the presence of violence during the act and supported the narrative of rape with homicide.

The accused voluntarily made an extra-judicial confession wherein he admitted to raping and subsequently strangling the victim.
This confession was recorded in a detailed narrative that included specifics of his actions—from purchasing liquor, his movements prior to the crime, and the step-by-step description of the assault and the victim’s subsequent death.
The confession was taken in the presence of law enforcement officers and later confirmed in written form by the signing of a Pagpapatunay, asserting that the accused was duly informed of his constitutional rights and waived them.

During trial, the accused testified that he simply returned home after work and later found his common-law wife holding the lifeless body of the victim.
He denied having raped or killed the victim, offering an alternate sequence of events which contradicted the detailed confession and other evidence.

The Regional Trial Court found the accused guilty beyond reasonable doubt of the complex crime of rape with homicide.
The court imposed reclusion perpetua and awarded damages comprising actual, moral, and exemplary categories, though some of these awards were later subject to modification.

The contention that his extra-judicial confession was taken in violation of his constitutional right to competent and independent counsel of his choice.
Allegations of insufficiency in the prosecution’s evidence, claiming that the prosecution witnesses were merely “witnesses after the fact.”
Challenges over the weight given to the prosecution evidence and the appropriateness of the damages awarded.

The Solicitor General maintained that all constitutional safeguards during custodial investigation were observed and disputed the defense’s claims regarding the voluntariness and admissibility of the confession.

Whether the accused’s Sinumpaang Salaysay was voluntarily made, free from coercion or intimidation.
Whether it was executed with the assistance of a competent and independent counsel, in compliance with constitutional requirements.

Whether the body of evidence, including the confession and corpus delicti (medical and forensic findings), was sufficient to establish guilt beyond reasonable doubt.

Whether the accused’s right to have a counsel of his own choice was violated during the custodial investigation and execution of the confession.

Whether the trial court correctly awarded actual damages and whether modifications on the quantum of moral and exemplary damages were warranted.