G.R. No. 90010-11 - Cagayan Capitol College vs. National Labor Relations Commission

On November 12, 2003, victim AAA requested permission from her mother (BBB) to accompany Noli Villegas, Jr. y Lacrete (the accused) to visit a friend in a neighboring barangay in Estancia, Iloilo.
Although BBB denied the request, AAA left the house and was later seen with Villegas near a jetmatic pump in Barangay x x x.
At around 5:30 p.m., Felicidad Bornales, while fetching water at the pump, observed AAA in the company of Villegas, who was wearing a white t-shirt, maong pants, and carrying a dark blue bag.
During the conversation, Villegas reportedly invited AAA to go to the nearby mountain, but she declined for fear of her mother’s reaction.

By 8:00 p.m., BBB grew worried when AAA had not returned home and, with the help of neighbors (including her daughter CCC and a local child), began searching.
The group first visited the house of Eva Catalan (Villegas’ aunt), who denied knowledge of AAA’s whereabouts.
Shortly after departing, they followed sledge prints leading to an abandoned house owned by Antonio Lacrete, located approximately 35 meters away.
Inside the abandoned house, they discovered several items:

A white T-shirt, a pair of black slippers with green straps, and a pair of yellow slippers linked to AAA.
Blood stains on the bamboo floor.
A dark-blue bag containing personal effects of Villegas, including a tattered birth certificate and money.

On November 14, 2003, after being informed by an intermediary (a certain Nico) that AAA’s body had been found dumped in a pond along a rice field, Villegas, accompanied by his father, voluntarily surrendered to authorities.
An Information was filed on April 28, 2004 charging him with rape with homicide.
During arraignment, Villegas pleaded “not guilty,” and during the pre-trial, the parties only stipulated to his identity as the accused.

The medical findings of Police Chief Inspector Owen Jaen Lebaquin, who reported a traumatic head injury causing intracranial hemorrhage, multiple contusions, abrasions, and evidence that AAA had recently lost her virginity.
The Sinumpaang Salaysay (sworn statements) of BBB and Felicidad Bornales detailing:

The timeline of events from AAA’s departure to the discovery of evidence.
Observations at the jetmatic pump and the subsequent discovery of physical evidence at the abandoned house.

Testimonies also included conflicting accounts concerning the relationship between AAA and Villegas:

Felicidad Bornales and BBB’s accounts indicated a relationship and a sequence of events that placed Villegas at the scene.
Eva Catalan and Ronilo (Villegas’ uncle) provided an alibi and asserted that AAA and Villegas were “sweethearts,” though these accounts were later found to be inconsistent.
Villegas himself maintained that he was merely on an errand and had only last seen AAA while helping her fetch water.

The Regional Trial Court (RTC) rendered its decision on December 15, 2011, convicting Villegas of rape with homicide based solely on the circumstantial evidence.
The RTC observed that:

The evidence consistently pointed to Villegas, the last person seen with AAA before her disappearance.
Items belonging to both the victim and the accused were found at the abandoned house, suggesting the crime was committed there.
The proximity of the abandoned house to the scene and the accessibility of the location negated any plausible alibi.

Accordingly, the RTC sentenced Villegas to reclusion perpetua, coupled with accessory penalties, including orders for compensatory awards to the victim’s heirs (death indemnity and moral damages).
Villegas subsequently appealed the conviction, arguing insufficiency of the circumstantial evidence and flaws in the evidentiary evaluation, particularly with respect to his alibi defense.

Whether the chain of circumstantial evidence, including physical evidence from the abandoned house and the converging testimonies of prosecution witnesses, established Villegas’ guilt beyond reasonable doubt.
Whether the inconsistencies noted among witness testimonies undermined the reliability of the evidence presented.

Whether the defense’s reliance on an alibi—corroborated mainly by close relatives and questionable witness statements—was sufficient to counter the prosecution’s narrative.
The extent to which the accessible nature of the abandoned house and surrounding area affected the validity of the alibi.

The issue of whether the testimonies of prosecution witnesses (e.g., Felicidad Bornales and BBB) should outweigh the contradictory accounts provided by defense witnesses, including those supporting Villegas’ assertion of a romantic relationship and an alibi.
Whether the trial court’s deference to the demeanor and observational evidence of witnesses was justified.

Whether the sanction of reclusion perpetua (without eligibility for parole) alongside the imposed monetary awards complied with statutory mandates and recent jurisprudence.
The legal standard for adjusting compensatory damages in cases involving complex crimes like rape with homicide.