Case Digest (G.R. No. 167746)
Facts:
People of the Philippines v. Delfin Rondero, G.R. No. 125687, December 09, 1999, the Supreme Court En Banc, Per Curiam. The respondent is Delfin Rondero (accused-appellant); the prosecution is the People of the Philippines (plaintiff-appellee). The case reached the Court on appeal from the Regional Trial Court (RTC) of Dagupan City, Branch 41, which first convicted Rondero of murder (October 13, 1995) and sentenced him to death, then, on motion for reconsideration (November 10, 1995), amended the conviction to homicide and imposed reclusion perpetua pursuant to Section 10 of R.A. No. 7610.On the night of March 25–early morning of March 26, 1994, nine‑year‑old Mylene J. Doria disappeared after a barrio fiesta. Her father, Maximo Doria, and neighbors searched and, at about 1:00 a.m., Maximo claimed to have seen accused-appellant at an artesian well about one meter from his house, washing bloodied hands with an ice pick clenched in his mouth. Later they found Mylene’s lifeless, partially nude body near the Pugaro Elementary School with extensive head injuries, hymenal and labial lacerations, abrasions and contusions; the autopsy (Dr. Tomas Cornel) showed massive intracranial hemorrhage and fractured occipital bone as cause of death. A pair of slippers and hair strands were recovered at the scene; one slipper reportedly bore a red‑painted leaf which Maximo identified as belonging to Rondero.
Police arrested accused-appellant after Maximo led them to the artesian well, and the officers later seized Rondero’s undershirt and short pants from his clothesline. Initial NBI testing required pulled (not cut) hair samples; later hair strands from the victim, from the scene, and pulled hairs from Rondero were microscopically compared by the NBI forensic chemist, who testified that the hair found on the victim’s right hand matched characteristics of Rondero’s hair. Rondero pleaded not guilty and did not testify; his wife and father testified that he had been involved in an earlier quarrel and was bleeding from blows inflicted by his father the night before, and that his wife washed his bloodstained clothes early morning March 26.
The RTC trial judge initially convicted for murder and sentenced Rondero to death; on reconsideration the RTC reduced the conviction to homicide and imposed reclusion perpetua under R.A. No. 7610 because the victim was under twelve. The People appealed to the Supreme Court. The Supreme Court reviewed the record, resolved contested evide...(Subscriber-Only)
Issues:
- Was the evidence, largely circumstantial, sufficient to convict accused-appellant beyond reasonable doubt?
- Were the hair specimens and the accused’s bloodstained garments admissible in evidence given allegations of coercion and illegal search and seizure?
- Did the warrantless arrest and alleged custodial irregularities vitiate the prosecution and require dismissal or reversal?
- Should the conviction be for the special complex crime of rape with homicide and, if so, is the death penalty properl...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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