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
Case Digest (G.R. No. 185012)
Facts:
On August 3, 1995, an Information was filed against Victor Villarino y Mabute, charging him with the special complex crime of rape with homicide. The allegations stated that on April 29, 1995, at around 5:00 PM in Barangay "D1", Almagro, Samar, the accused, with lewd design and by means of force, violence, and intimidation, had carnal knowledge of a ten-year-old girl, referred to as "AAA", without her consent. Following the act, he allegedly inflicted mortal wounds on her, resulting in her death. The appellant pleaded not guilty, and the trial commenced after a pre-trial conference.
The prosecution's case revealed that on April 28, 1995, "BBB", the mother of "AAA", took her daughter and son to a relative's house in Barangay "D" for a fiesta. On the morning of April 29, "AAA" was sent home to fetch a t-shirt for her brother but did not return. "BBB" later learned that a dead child had been found in Barangay "D1", where she identified her daughter's body. The victim was discovered in a compromising position, with signs of sexual assault and violence. Jewelry belonging to the appellant was found at the crime scene, and he was later arrested while intoxicated and violent. During his arrest, bloodstains were found on his clothing, and he spontaneously confessed to the crime to a police officer, offering to give ...