Case Digest (G.R. No. 128647)
Facts:
People of the Philippines v. Antonio "Tony" Salonga, Alfredo "Fred" Danganan and Eduardo "Eddie" Danganan, G.R. No. 128647, March 31, 2000, the Supreme Court En Banc, Per Curiam, writing for the Court.The accused were charged by information with rape with homicide allegedly committed on November 10, 1994 against 13‑year‑old Babylyn Garcia in Tarlac. The information alleged that the three defendants, "with the use of a bladed instrument and other hard object, conspiring, confederating and helping with one another," had carnal knowledge of the victim by force and then stabbed and beat her, causing death. The accused pleaded not guilty at arraignment.
At trial the prosecution presented eyewitness testimony and forensic evidence. Maximo Tabag testified he saw three men — whom he later identified as the three accused — dragging an unconscious, bloodied woman and dumping her in cogon grass near the Tarlac River. Jesusa Bartolome placed a man later identified as Antonio Salonga sitting in the shallow river wearing a brown bamboo hat and a sky‑blue long‑sleeved polo. The victim’s uncle and barangay officials discovered the body the next morning; the scene yielded the victim’s school ID, a woman’s shoe and human footprints. The police recovered a brown hat from Antonio Salonga’s household; NBI laboratory testing (Biology Report No. E‑94‑1423) showed the hat and certain cloths gave positive results for human blood of Group A. The autopsy report showed skull fracture, multiple stab wounds, laceration of the hymen and other injuries consistent with force and sexual assault.
The trial court (Regional Trial Court, Branch 65, Tarlac) weighed credibility, found the defense alibi and witnesses not credible, and on February 27, 1996 convicted all three accused of rape with homicide under Article 335, as amended by R.A. 7659, imposing the death penalty on each and awarding damages. Because the trial court imposed death, the case was transmitted to the Supreme Court for automatic review under Article 47 of the Revised Penal Code as amended by Section 22 of R.A. 7659. The accused-appellants urged reversal primarily on the ground that the circumstantial evidence was insufficient t...(Subscriber-Only)
Issues:
- Was the conviction of the accused sustainable beyond reasonable doubt on the basis of the circumstantial and testimonial evidence presented?
- Was the imposition of the death penalty proper under Article 335 as amended by R.A. 7659?
- Were the civil and exemplary damage awards appropriate, and if not, what prop...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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