Case Summary (G.R. No. 173510)
Key Dates
March 17, 1995 – Date of the crime
March 18, 1995 – Discovery of victim’s body
March 3, 1999 – RTC judgment convicting appellant
February 9, 2006 – CA decision affirming with modification
March 15, 2010 – Supreme Court decision
Applicable Law
1987 Philippine Constitution (due process, right to counsel)
Revised Penal Code, Article 335 as amended by RA 7659 (rape with homicide)
RA 9346 (abolition of death penalty)
Rule 133, Sec. 4, Rules of Court (circumstantial evidence)
Factual Background
“AAA” walked daily through the farm’s plantation to catch transport to school. On March 17, 1995, she failed to return home. The following morning her body was found concealed by leaves, with a vine around her neck, head wounds, disheveled uniform, and missing undergarments. Autopsy confirmed rape (hymenal lacerations) and death by strangulation and blunt trauma.
Prosecution Evidence
- Opportunity and familiarity: Appellant lived and worked as stay-in security guard at the crime site.
- Lewd behavior: Witnesses, including the victim’s aunt, testified appellant made sexual advances toward “AAA.”
- Identification and threats: Juanito saw appellant alone with unconscious “AAA” around 1–2 PM, wearing only shorts, ordering him at pistol-point to tie a vine around her neck. Appellant threatened Juanito’s life and family if he spoke.
- Physical indicators: Juanito observed the victim without undergarments; appellant bore fresh scratches on arms, neck, and back consistent with fingernail marks.
- Flight and restlessness: Appellant absconded after withdrawing his counsel’s waiver and was later arrested in Northern Samar two years later.
Defense Evidence
Appellant denied acquaintance with “AAA,” claimed an alibi placing him elsewhere from midnight to 3 PM on the crime day, and alleged false accusation motivated by a farm-land dispute. He challenged the reliability of prosecution witnesses and asserted procedural irregularities in his detention and interrogation without counsel.
RTC Ruling
The Regional Trial Court (Branch 21, Malolos) found the prosecution proved the complex crime of rape with homicide beyond reasonable doubt. Appellant was sentenced to death by lethal injection (per Article 335 RPC) and ordered to pay civil and moral damages.
CA Ruling
The Court of Appeals affirmed the conviction but modified civil indemnity from ₱50,000 to ₱100,000. The death sentence stood pending Supreme Court review.
Issue on Appeal
Whether the circumstantial evidence was sufficient to convict appellant of the complex crime of rape with homicide beyond reasonable doubt.
Circumstantial Evidence Doctrine
Under the 1987 Constitution and Rule 133, Sec. 4, conviction may rest on circumstantial evidence if (1) multiple circumstances are proven, (2) those facts are established, and (3) they form an unbroken chain pointing to the accused to the exclusion of all others.
Supreme Court Analysis and Application
- Opportunity and motive aligned with appellant’s role as guard and his known lewd interest in the victim.
- Juanito’s unshaken testimony, corroborated by Martin and Arnel, detailed appellant’s threats and directives at pistol-point.
- Physical scratches on appellant matched defensive wounds of the victim.
- Absence from duty post-crime, withdrawal of counsel’s waiver, and flight e
Case Syllabus (G.R. No. 173510)
Procedural Posture
- Petition for review on certiorari filed before the Supreme Court under G.R. Nos. 173510 and 174099, consolidated due to common parties and issues.
- RTC of Malolos, Bulacan, Branch 21 convicted appellant of the complex crime of rape with homicide and sentenced him to death (later modified to reclusion perpetua).
- CA in CA-G.R. CR-H.C. No. 01384 affirmed with modification civil indemnity, increasing it from ₱50,000 to ₱100,000.
- Supreme Court review raises the sufficiency of circumstantial evidence and issues on penalty and damages.
Factual Antecedents
- Victim “AAA,” a 13-year-old first year high school student, walked daily through a 50-hectare plantation in San Jose del Monte, Bulacan, where appellant worked as a stay-in security guard.
- On March 17, 1995, “AAA” did not return home; her body was found the next morning inside the plantation.
- Corpse covered with leaves, panty missing, blouse crumpled; a wood vine tied around her neck.
- Medico-legal exam: death by asphyxia due to strangulation and traumatic injuries; lacerations in hymen consistent with recent loss of virginity; defensive wounds on forearm.
Prosecution’s Evidence
- Juanito Manalo III saw appellant beside the unconscious victim at around 1–2 P.M., clad only in shorts, waving a pistol.
- Appellant forced Juanito under threat to tie a vine around “AAA”’s neck and to touch her body; threatened to kill Juanito and his family if he spoke.
- Witnesses Martin Gailan and Arnel Alminana corroborated Juanito’s account of threats.
- Appellant reported scratched arms, neck, and back when questioned by police—consistent with fingernail marks.
- Prior lewd conduct: appellant allegedly whistled at and touched “AAA” on several occasions; warned her aunt to “watch over” her niece.
- Appellant absconded during trial, later arrested in Northern Samar.
Defense’s Evidence
- Appellant denied knowing “AAA” and alleged alibi: at Balete farm center until 10 A.M. and at Montalban, Rizal, by 3 P.M. on March 17, 1995.
- Claimed false accusation motivated by land dispute between victim’s family and farm owners.
- Contended initial police detention,