Case Summary (G.R. No. L-45255)
Charges and Trial Proceedings
Raymundo Corfin was charged with robbery with homicide, specifically the crime of Rape with Homicide, based on events that transpired on May 18, 1995. Upon arraignment, Corfin pleaded not guilty, and the trial commenced, revealing uncontroverted facts surrounding the child’s tragic death.
Circumstantial Evidence and Witness Testimonies
Due to the absence of eyewitnesses, the prosecution relied on circumstantial evidence and the testimonies of various witnesses, including neighbors of the Zabala family. Key testimonies indicated Corfin’s last seen interaction with Ad Jane before she was found deceased the following day. Multiple witnesses corroborated seeing Corfin conversing with the victim, engaging in activities near the crime scene, and being identified as the individual last seen with her.
Accused-Appellant's Defense
The defense presented Corfin as the sole witness, asserting an alibi that placed him away from the crime during the time of the incident. He claimed to have been home during the crucial hours and denied any interaction with Ad Jane. However, his claims were directly contradicted by the witness testimonies that identified him in proximity to the victim.
Trial Court's Decision
The Regional Trial Court found Corfin guilty beyond a reasonable doubt and sentenced him to death, recognizing the gravity of the crimes he was charged with. The court relied on the established circumstantial evidence to substantiate the conviction, although the prosecution's evidence did not conclusively prove the charge of rape.
Appellant's Arguments on Appeal
On appeal, Corfin contended that his conviction was unjustly based on circumstantial evidence lacking sufficient weight to establish guilt beyond a reasonable doubt. He emphasized the absence of definitive evidence pinpointing him as the perpetrator, claiming it only created a possibility of his involvement.
Legal Standards for Conviction Based on Circumstantial Evidence
The court outlined key legal standards pertinent to convictions driven by circumstantial evidence, detailing the requirements that: multiple circumstances must exist; the underlying facts must be proven; and the combination of circumstances must lead to a single reasonable conclusion of culpability.
Court's Analysis of Circumstantial Evidence
The court deemed the presented circumstantial evidence adequate to convict Corfin, as it established a direct nexus between him and the victim's death. His presence at the scene, identifiable clothing, and the timeline of events created an unbroken chain of evidence pointing to his guilt.
Conclusions on Rape Charge
While the
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Case Overview
- The case is an automatic review of the decision rendered on August 13, 1997, by the Regional Trial Court (RTC) of General Santos City, Branch 35.
- Raymundo Corfin was found guilty beyond reasonable doubt of the crime of Rape with Homicide and was sentenced to death.
- The information filed charged Corfin with robbery with homicide, specifically involving the rape and subsequent murder of a 4-year-old girl, Ad Jane Zabala.
Facts of the Case
- On May 18, 1995, Rosemarie Zabala took her youngest child for immunization and found her daughter Ad Jane missing upon returning home.
- Alejandro Zabala, Ad Jane's father, reported her disappearance to the police after searching for her unsuccessfully.
- On May 19, 1995, Ad Jane's body was discovered in a dry creek, showing signs of violence and sexual assault.
- An autopsy revealed severe injuries consistent with rape and homicide, leading to the conclusion that she died from hemorrhage caused by the assault.
Prosecution's Evidence
- Witnesses testified to seeing Corfin conversing with Ad Jane near an abandoned store on the morning of her disappearance.
- Multiple neighbors identified Corfin as the last person seen with the victim before her body was found.
- Testimonies indicated Corfin was seen leaving the vicinity of the crime and exhibited signs of distress.
Defense
- Corfin denied the allegations, asserting he was at home during the time of the cr