Case Summary (G.R. No. 100912)
Judgment and Sentence
The judgment, rendered on March 18, 1991, found Zaldy Cristobal guilty beyond reasonable doubt of the complex crime of rape with homicide, as defined under Article 335 of the Revised Penal Code. He was sentenced to reclusion perpetua along with accessory penalties, directed to indemnify the heirs of the deceased with the amount of P30,000, and incurred the costs of the trial. The court recognized that the accused's detention would be credited fully toward his sentence.
Appeal Errors Raised by the Accused
On appeal, Zaldy Cristobal challenged the trial court's decision on several grounds: first, claiming that the court improperly believed the inconsistent testimony of Teresa Cantubira, a prosecution witness; second, that the court wrongly concluded that he was guilty based on circumstantial evidence; and third, that the evidence did not support a conviction of rape with homicide but rather of a lesser offense.
Prosecution Evidence
Key prosecution witnesses included Ruben Escota, Pedra Cristobal, Conrado Monterola, and Teresa Cantubira. They provided testimonies establishing the accused's drunken state prior to the crime, his threats to kill the victim, and eyewitness evidence of the assault. Particularly, Teresa Cantubira testified that she witnessed the accused attacking Edna, during which he was completely naked and was stabbing her while she cried out for help.
Autopsy Findings
Dr. Luis L. Aguirre, the Municipal Health Officer, conducted the autopsy on the victim, revealing a significant number of wounds: a total of 18 incised wounds and 20 stab wounds. This medical evidence corroborated the violent nature of the attack, revealing the brutal manner in which Edna was killed.
Defense and Rebuttal
In his defense, Zaldy Cristobal denied involvement in the crime, asserting that he was working at the benefit dance on the night of the incident. His defense relied heavily on alibi and a denial of the allegations, which were contradicted by rebuttal witness Elvis Cantubira, who discredited Cristobal's alibi, confirming that he last saw the accused at the plaza before the victim was attacked.
Evaluation of Evidence and Verdict
The trial court's assessment was primarily centered on the credibility of witness testimonies. The court determined that the direct and circumstantial evidence presented supported the conviction. The eyewitness account by Teresa Cantubira was particularly persuasive, and in conjunction with the medical findings, it resulted in an affirmation of the accused's guilt beyond reasonable doubt.
Modification of Civil Indemnity
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Case Overview
- This case involves an appeal from a judgment of the Regional Trial Court of Masbate, which convicted Zaldy Cristobal y Albarin of the complex crime of Rape with Homicide.
- The incident occurred on the evening of September 22, 1989, in barangay Mabato-bato, Municipality of Mandaon, Masbate, Philippines.
- The prosecution asserts that Cristobal, armed with a sharp instrument, raped and subsequently killed Edna Cantubira.
Information and Charges
- The Information dated January 12, 1990, details the charges against Zaldy Cristobal.
- The charge states that Cristobal committed carnal knowledge with Edna Cantubira against her will, using force and intimidation, and inflicted fatal wounds upon her, leading to her death.
Arraignment and Conviction
- Zaldy Cristobal pleaded not guilty when arraigned on March 12, 1990.
- The trial culminated in a judgment on March 18, 1991, where he was found guilty beyond reasonable doubt of Rape with Homicide.
- The court sentenced him to reclusion perpetua, mandated indemnification of the victim’s heirs in the amount of P30,000.00, and ordered the crediting of his detention period against his sentence.
Appellant's Assignments of Error
- Cristobal's appeal assigns several errors to the trial court, including:
- Crediting the inconsistent testimony of prosecution witness Teresa Cantubira.
- Convicting him based on circumstantial evidence.
- Finding him guilty beyond reasonable doubt of Rape with Homicide.