Title
People vs. Sace y Montaya
Case
G.R. No. 178063
Decision Date
Apr 5, 2010
A man appeals his conviction for rape with homicide, claiming he found the victim's body and chased unidentified men, but the Supreme Court affirms his guilt based on circumstantial evidence, including a positive identification by the victim's brother and the appellant's voluntary confession.
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Case Digest (G.R. No. 178063)

Facts:

  • Tirso Sace y Montoya was charged with rape and homicide.
  • The incident occurred on September 9, 1999, around 7:00 PM in Barangay Tabionan, Gasan, Marinduque, Philippines.
  • Victim AAA was at home with her 10-year-old brother BBB and a toddler nephew.
  • Sace, who had been drinking since 11:00 AM, arrived and made sexual advances towards AAA.
  • Sace pulled out a bladed weapon and chased AAA upstairs.
  • BBB heard Sace threatening AAA to remove her clothes or be stabbed.
  • CCC, the mother of AAA and BBB, arrived home and found Sace bloodied, claiming he was chasing someone.
  • AAA's lifeless, half-naked body was found nearby.
  • Sace initially denied involvement but later confessed to barangay officials and tanods.
  • The RTC of Boac, Marinduque, convicted Sace on June 1, 2001, sentencing him to death, later reduced to reclusion perpetua by the Court of Appeals on November 20, 2006.
  • Sace appealed, claiming the circumstantial evidence was insufficient to prove his guilt beyond reasonable doubt.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the conviction of Tirso Sace y Montoya for rape with homicide.
  • The Court upheld the Court of Appeals' decision, reducing the penalty from death to reclusion perpetua.
  • The Court modified the damages awarded, incre...(Unlock)

Ratio:

  • Proof beyond reasonable doubt requires moral certainty, not absolute certainty.
  • Circumstantial evidence can be sufficient to establish guilt when direct evidence is unavailable.
  • The prosecution's evidence established a chain of events pointing to Sace's guilt: his drunken state, his attempt to embrace AAA, his chase with a knife, his bloodied appearance, and his voluntary confession.
  • BBB's testimony was credible and consistent, positively identifying Sace as the perpetrator.
  • Sace's defense of denial and alibi was weak and unsupported by strong evidence.
  • Sace'...continue reading

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