Title
Supreme Court
People vs. ZZZ
Case
G.R. No. 228828
Decision Date
Jul 24, 2019
ZZZ, a minor, convicted of rape with homicide based on circumstantial evidence, including witness testimony, medical findings, and flight. Court ruled he acted with discernment, sentencing him to 10-17 years and ordering damages to AAA’s family.

Case Digest (G.R. No. 228828)
Expanded Legal Reasoning Model

Facts:

  • Procedural History
  • On October 14, 1996, the prosecution filed an Information charging ZZZ with the special complex crime of rape with homicide for the May 16, 1996 attack on AAA, alleging force, intimidation, skull fracture, genital laceration, and death.
  • ZZZ remained at large until his arrest on February 6, 2003; he pleaded not guilty upon arraignment before RTC Branch 56 and was tried.
  • The RTC rendered judgment on March 4, 2013 finding ZZZ guilty; the Court of Appeals affirmed on February 29, 2016; ZZZ appealed to the Supreme Court (G.R. No. 228828).
  • Prosecution Evidence
  • BBB (uncle of AAA and cousin of ZZZ) testified seeing ZZZ dragging AAA by the wrist at about 7 p.m. on the night in question, then later joined search efforts when she went missing; AAA’s decomposed body was found in a nearby bamboo grove, and BBB last saw ZZZ at his home that day.
  • SPO3 Jaime Lavarias, responding officer, identified the corpse via BBB, prepared the investigation report, obtained YYY’s initial statement that he was with ZZZ and AAA before being told to leave them, and arranged an autopsy.
  • Dr. Paz Q. Mejia conducted a preliminary autopsy on May 20, 1996, noting a cracked temporal skull, brain matter leakage, a ½-inch laceration on the left labia, and advanced decomposition; she opined the skull fracture may have caused death.
  • Dr. Ronald Bandonill’s NBI autopsy on May 29, 1996 confirmed advanced decomposition, contusions on the face, right arm, thighs, and genital area consistent with a blunt instrument, a vaginal tear with dried blood, and traumatic cerebral contusion as the cause of death.
  • CCC (AAA’s father) testified AAA was 11 years old, incurred PHP 20,000 for her internment and PHP 30,000 for other expenses, and claimed damages for his daughter’s death.
  • Defense Evidence
  • ZZZ, age 15 at the time, presented his birth certificate and testified he and his brother spent the night at their grandmother’s home watching television, did not observe AAA leave, and that his stepfather later took him to work in Tarlac under an alias.
  • YYY (ZZZ’s brother) recanted his police statement, testified he accompanied ZZZ and AAA home before sleeping at their sister’s house, and corroborated the alibi.

Issues:

  • Guilt
  • Whether ZZZ is guilty beyond reasonable doubt of the special complex crime of rape with homicide.
  • Discernment
  • Whether the prosecution proved that ZZZ, who was 15 years old at the time, acted with discernment under Republic Act No. 9344.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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