Case Digest (G.R. No. 219185)
Facts:
In People of the Philippines vs. Edmundo Villaflores y Olano, the victim, Marita (a female minor born October 29, 1994), went missing on the morning of July 2, 1999, while playing behind her home in Phase 9, Bagong Silang, Caloocan City. Her parents, Julia and Manito, searched until late that evening and, following a clairvoyant’s tip, discovered Marita’s lifeless body the next morning in the comfort room of an abandoned house about five houses away. The body was covered by a blue sack, a yellow sack was found under her head, and a nylon cord was around her neck. Autopsy by Dr. Jose Arnel Marquez revealed multiple deep lacerations in the hymen, vaginal congestion with spermatozoa in genital smears, and death by asphyxia due to strangulation, indicating rape with homicide. Two neighborhood drug-user witnesses, Aldrin Bautista and Jovie Solidum, testified they had seen Villaflores leading Marita by the hand and later carrying a heavy yellow sack toward the abandoned house. PhysicaCase Digest (G.R. No. 219185)
Facts:
- Incident and victim
- Marita, born October 29, 1994 (Exh. K), aged four years and eight months on July 2, 1999, went missing while playing near her home in Bagong Silang, Caloocan City.
- On July 3, 1999 at about 6 am, her father reported her missing; following a clairvoyant’s hint, her lifeless body was found inside the comfort room of an abandoned house five structures from her home, covered by a blue and yellow sack. Her face was black and blue, bloody, tortured, and strangled to death.
- Investigation and evidence
- Witnesses Aldrin Bautista and Jovie Solidum testified they saw Edmundo “Batman” Villaflores leading Marita by the hand at around 10 am on July 2, 1999; at about 3 pm Solidum heard a child crying inside Villaflores’s house; at about 7 pm he saw Villaflores carrying a heavy yellow sack toward the abandoned house.
- Physical evidence recovered at the crime scene included a nylon rope (Exh. N) and the yellow sack, both traced to Villaflores’s premises; a hidden rear pathway linked his house to the abandoned house.
- Forensic findings
- Autopsy (July 3, 1999 at ~8 pm) by Dr. Arnel Marquez: multiple head contusions, hematomas, abrasions, deep fresh hymenal lacerations, congested genitalia with spermatozoa, ligature mark on neck; stomach contained partly digested food. Cause of death: asphyxia by strangulation; body in secondary flaccidity, indicating death more than 24 hours earlier.
- Trial and appellate history
- RTC, Branch 128, Caloocan City (May 27, 2004): convicted Villaflores of rape with homicide; imposed death penalty; civil indemnity ₱75,000; moral damages ₱30,000; exemplary damages ₱20,000.
- CA, Third Division (Feb 22, 2007): affirmed conviction; commuted death to reclusion perpetua; modified civil indemnity to ₱100,000; moral damages ₱75,000; actual damages ₱52,000.
- Supreme Court review: raised issues on sufficiency of circumstantial evidence and composite crime nature.
Issues:
- Whether the State proved beyond reasonable doubt that Villaflores raped and, by reason or on the occasion thereof, killed Marita, relying on circumstantial evidence.
- Whether the composite nature of rape with homicide under R.A. 8353 and the rules on circumstantial evidence were correctly applied.
- Whether the penalties and awards of damages as modified by the CA are proper and complete.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)