Case Summary (G.R. No. 206226)
Factual Background
On the night of March 11, 2001, Constancio and Berry, along with other co-accused, forcibly abducted "AAA" outside the Alabang Town Center. The Information filed against them detailed the unlawful acts, including rape and murder, asserting that the accused attacked and strangled "AAA," resulting in her death. Berry and Constancio pleaded not guilty during their arraignment on May 3, 2001.
Prosecution's Evidence
The prosecution’s case relied on witness testimonies which included the victim's mother, "BBB," who recounted the events leading to her daughter's abduction, rape, and murder. Other witnesses included classmates of "AAA," who provided time-stamped accounts of their last interactions with her. Forensic evidence was presented by Dr. Emmanuel Reyes, who established the cause of death as asphyxia due to strangulation, and additional testimonies highlighted the actions of the appellants before and after the crime.
Defense's Case
The defense raised alibi as the basis for acquittal, asserting that Berry was not involved in the crime despite his confession, which he claimed was coerced. Constancio maintained that he was in a different location during the events in question, suggesting he was wrongly implicated. Testimonies from the defense witnesses attempted to discredit the prosecution's narrative, but were not sufficient to dismantle the strong corroborative evidence presented against the accused.
Ruling of the Regional Trial Court
On January 23, 2007, the Regional Trial Court (RTC) found Constancio and Berry guilty beyond reasonable doubt of Rape with Homicide, sentencing them to reclusion perpetua and ordering them to jointly pay damages to the heirs of "AAA." The acquittal of co-accused Pagkalinawan was also pronounced due to lack of evidence linking him directly to the crime.
Ruling of the Court of Appeals
On February 24, 2012, the Court of Appeals affirmed the RTC's decision, concluding that the appellants conspired to commit the crime and that the testimonies provided by eyewitnesses were credible. The appellate court considered Berry's extrajudicial confession as admissible evidence and supportive of the prosecution’s allegations against both him and Constancio. This ruling was based on the circumstantial evidence present in the case, which linked both accused to the commission of the crime.
Key Legal Issues Raised on Appeal
The appellants raised several issues on appeal, notably questioning the credibility of prosecution witnesses as well as the admissibility of Berry's extrajudicial confession. They argued that the testimonies should not have been relied upon due to alleged incons
...continue readingCase Syllabus (G.R. No. 206226)
Case Background
- This case revolves around the appeal of Nieves Constancio y Bacungay (Constancio) and Ernesto Berry y Bacungay (Berry) against the decision of the Regional Trial Court (RTC) of ParaAque City which found them guilty of Rape with Homicide.
- The RTC's decision was rendered on January 22, 2007, and subsequently affirmed by the Court of Appeals (CA) on February 24, 2012.
- The appellants were sentenced to reclusion perpetua and ordered to pay damages to the heirs of the victim, referred to as "AAA."
Factual Antecedents
- The crime occurred on the night of March 11, 2001, in ParaAque City, where Constancio, Berry, and their co-accused were charged with abducting, raping, and murdering "AAA."
- The Information detailed the use of force and intimidation leading to "AAA's" carnal knowledge against her will, followed by physical assault resulting in her death.
Version of the Prosecution
- Witness Testimonies:
- "BBB" (Victim's Mother): Testified about her daughter's abduction, rape, and murder, leading to the discovery of "AAA's" body in a creek.
- Myra Katrina Dacanay: Described the events on the night of the incident, including her attempts to contact "AAA" after she did not return home.
- Tara Katrina Golez: Confirmed her presence with "AAA" prior to the incident and her inquiries about "AAA's" whereabouts after the event.
- Janette Bales: Identified Berry as the man who attempted to abduct her shortly after "AAA's" murder, providing critical identification of the accused.
- Dr. Emmanuel Reyes: Conducted the autopsy, revealing the cause of death as asphyxia by strangulation and traumatic injuries consistent with a violent assault.
- Chito Adarna: Witnessed the two accused disposing of "AAA's" body and positively identified them in court.
- P/Sr. Insp. Edgardo C. Ariate: Provided details on the investigation process, including the eventual ide