Title
People vs. Villarino y Mabute
Case
G.R. No. 185012
Decision Date
Mar 5, 2010
A man is convicted of rape with homicide based on circumstantial evidence and an admissible unsolicited confession to the police.
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Case Digest (G.R. No. 185012)

Facts:

  • On August 3, 1995, an Information was filed against Victor Villarino y Mabute for the special complex crime of rape with homicide.
  • The incident occurred on April 29, 1995, in Barangay "D1", Almagro, Samar, involving a ten-year-old girl referred to as "AAA".
  • The accused allegedly had carnal knowledge of "AAA" without her consent, using force and intimidation, and subsequently killed her.
  • "AAA" was last seen on April 29 when her mother, "BBB", sent her home to fetch a t-shirt for her brother.
  • "BBB" later identified her daughter's body in Barangay "D1", which showed signs of sexual assault and violence.
  • Jewelry belonging to the appellant was found at the crime scene.
  • Villarino was arrested while intoxicated and violent, with bloodstains on his clothing.
  • He spontaneously confessed to the crime to a police officer, offering jewelry in exchange for disposing of evidence.
  • The Regional Trial Court convicted Villarino of rape with homicide on May 19, 1999, sentencing him to death.
  • The Court of Appeals modified the ruling, convicting him only of homicide.
  • Dissatisfied, Villarino appealed to the Supreme Court, questioning the sufficiency of evidence for his conviction.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court dismissed the appeal and affirmed the conviction of Victor Villarino y Mabute for the complex crime of rape with homicide.
  • The Court found that the evidence, including the appellant'...(Unlock)

Ratio:

  • The Supreme Court stated that for a conviction of rape with homicide, the elements required include the appellant's carnal knowledge of the victim through force or intimidation, followed by the victim's killing.
  • In cases involving minors, evidence of sexual intercourse is sufficient for conviction.
  • The appellant's spontaneous confession was admissible as it was made without coercion and not during custodial interrogation.
  • Compelling circumstantial evidence in...continue reading

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