Title
People vs. Rama, Jr. y Ybanez
Case
G.R. No. 253467
Decision Date
Jun 27, 2022
An 11-year-old girl was raped and killed in a sugarcane field. Circumstantial evidence, including her dying declaration and the suspect's injuries, led to his conviction for rape with homicide, upheld by the Supreme Court.
A

Case Digest (G.R. No. 253467)

Facts:

  • Background and Charge
    • Pedro Rama, Jr. y YbaAez (appellant), was charged on February 15, 2013, with rape with homicide of an 11-year-old minor (AAA253467) occurring on February 12, 2013, at around 6:00 A.M. in Negros Occidental.
    • The Information stated the appellant wilfully and unlawfully had carnal knowledge of AAA253467 against her will and, to conceal his identity, killed her by strangling and mauling, resulting in her death.
  • Trial Court Proceedings
    • Appellant pleaded not guilty.
    • The prosecution presented testimony from:
      • BBB253467, mother of AAA253467;
      • CCC253467, brother of AAA253467;
      • Danilo Jimenez, a local resident;
      • Police Officer 3 Elizabeth Lopez of the Women and Child Protection Desk; and
      • Dr. Virgilio Tan, Medical Officer V at the city hospital.
    • Defense presented testimony from the appellant, his daughter Jeneth Rama, and friend Jolito Alba.
  • Prosecution's Version
    • On the morning of February 12, 2013, AAA253467 left to defecate in a nearby sugarcane field about 50 meters from her home. She did not return after half an hour.
    • Her mother and brothers searched for her and found her unconscious in the field. She was brought to the hospital but died two hours later.
    • Before her death, AAA253467 described her attacker as a neighbor with long hair and wearing a red and blue shirt, and that she scratched his right side.
    • CCC253467 saw appellant, shirtless, with mud, scratches, and blood on his right abdomen, hastily leaving the area.
    • Jimenez testified he saw appellant going to the sugarcane field around 5:00 A.M., wearing a red and blue shirt, and returning at 6:30 A.M. shirtless with body soiled and scratches.
    • PO3 Lopez recovered a red and blue shirt at the crime scene, identified by Jimenez as appellant’s. She arrested appellant who was found bearing scratches on his abdomen.
    • Dr. Tan testified that AAA253467 died of asphyxia due to intrathoracic injuries caused by rape, with findings of fresh hymenal lacerations, neck contusions consistent with strangulation, and other injuries. Examination of appellant showed abrasions consistent with defensive wounds inflicted by the victim.
  • Defense's Version
    • Appellant claimed he never left his home from 5:00 A.M. to 9:00 A.M., repairing their house post.
    • Jolito Alba and Jeneth Rama supported his alibi.
    • Appellant denied owning the red and blue shirt and having any scratches or injuries.
    • He admitted knowing AAA253467's mother but denied knowing the victim.
  • Trial Court Decision
    • Found appellant guilty beyond reasonable doubt of rape with homicide.
    • Imposed penalty of reclusion perpetua without parole eligibility.
    • Awarded P100,000 each as civil indemnity, moral and exemplary damages to heirs of victim, with 6% interest from finality.
  • Appeal to the Court of Appeals
    • Appellant argued inconsistencies in testimonies and maintained his alibi.
    • The Office of the Solicitor General (OSG) countered emphasizing consistent prosecution testimonies and the failure of appellant to show physical impossibility to be at the crime scene.
    • The Court of Appeals affirmed the conviction on December 12, 2019.
  • Appeal to the Supreme Court
    • Appellant sought acquittal.
    • Both parties adopted their briefs from the Court of Appeals.

Issues:

  • Whether the appellant is guilty beyond reasonable doubt of the special complex crime of rape with homicide committed against the minor victim.
  • Whether the evidence presented, particularly circumstantial evidence, suffices to establish appellant’s guilt.
  • Whether the penalty of reclusion perpetua without parole and the damages awarded were proper.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.