Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Antonio "Tony" Salonga, Alfredo "Fred" Danganan, and Eduardo "Eddie" Danganan as defendants-appellants. The events transpired on November 10, 1994, in Tarlac, Philippines. The accused were charged with the crime of rape with homicide under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659. The prosecution alleged that the accused, using a bladed instrument and other hard objects, conspired to commit rape against Babylyn Garcia, a 13-year-old girl, and subsequently killed her.

On the day of the incident, Babylyn left her home in Barangay Sta. Maria to attend school but failed to return at the expected time. Her father, Pablito Garcia, searched for her but could not find her. Later that evening, a local resident, Maximo Tabag, witnessed the three accused dragging an unconscious Babylyn, whose head was bloody, to a nearby cogonal area. The f...

Facts:

Incident Overview:
On November 10, 1994, Babylyn Garcia, a 13-year-old high school student, was raped and killed in Tarlac, Philippines. The accused, Antonio "Tony" Salonga, Alfredo "Fred" Danganan, and Eduardo "Eddie" Danganan, were charged with rape with homicide under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659.

Events Leading to the Crime:

• Babylyn left her home to attend school but failed to return by the expected time.
• Her father searched for her but found no trace until her lifeless body was discovered in a cogonal area near the Tarlac River.

Witness Testimonies:

• Maximo Tabag: Witnessed the accused dragging the unconscious and bloodied body of Babylyn to the cogonal area. He recognized the accused but did not intervene due to fear.
• Jesusa Bartolome: Saw Antonio Salonga near the crime scene, identified by his attire (brown hat and sky-blue polo shirt).

Evidence:

• Bloodstained hat belonging to Antonio Salonga was recovered and tested, confirming the presence of human blood.
• Autopsy revealed Babylyn sustained severe injuries, including a cracked skull, stab wounds, and lacerations, indicating rape and violent force.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Circumstantial Evidence:
   The Court ruled that circumstantial evidence, when consistent with guilt and inconsistent with innocence, is sufficient to establish guilt beyond reasonable doubt. The combination of witness testimonies, physical evidence (bloodstained hat), and autopsy findings pointed conclusively to the accused’s involvement.

2. Credibility of Witnesses:
   The Court upheld the trial court’s assessment of witness credibility, emphasizing that trial courts are in the best position to evaluate demeanor and sincerity. Minor inconsistencies in testimonies did not undermine their overall credibility.

3. Defense of Alibi:
   The defense of alibi was rejected as the accused failed to prove it was physically impossible for them to be at the crime scene. The prosecution’s evidence outweighed their claims.

4. Penalty:
   The crime of rape with homicide, under Article 335 of the Revised Penal Code as amended by R.A. 7659, mandates the death penalty. The Court imposed this penalty, noting its indivisible nature despite the presence of mitigating or aggravating circumstances.

5. Damages:
   The Court modified the damages awarded, increasing death indemnity to P100,000.00, reducing moral damages to P50,000.00, and limiting actual damages to P18,000.00 based on the evidence presented.