Case Summary (G.R. No. 164749)
Petitioner
People of the Philippines (Plaintiff-Appellee)
Respondent
Clemente John Lugod (Accused-Appellant)
Key Dates
- September 15–16, 1997: Commission of the offense
- October 10, 1997: Filing of Information for rape with homicide
- October 8, 1998: RTC conviction and imposition of death penalty
- February 21, 2001: Supreme Court decision
Applicable Law
- 1987 Philippine Constitution, Article III, Section 12 (rights of persons under investigation)
- Republic Act No. 7659, Section 11 (special complex crime of rape with homicide)
- Rule 113, Section 5(b), Rules of Court (warrantless arrest)
- Rule 133, Section 4, Rules on Evidence (circumstantial evidence)
Factual Background
On the night of September 15, 1997, Lugod was seen intoxicated, wearing distinctive rubber slippers (red-soled, yellow-and-white straps) and a black collared T-shirt. Multiple witnesses placed him at the victim’s home and at a nearby house in Villa Anastacia. Early on September 16, the victim’s mother discovered the child missing and found the accused’s slippers at the backdoor. A search party later recovered the victim’s soiled panty and the same black T-shirt near the site where the body was eventually found in a coconut plantation. The medico-legal officer testified to an 8 cm vulvar laceration and hypovolemic shock as cause of death.
Procedural History
The Regional Trial Court of Santa Cruz, Laguna (Branch 28) convicted Lugod of rape with homicide under RA 7659 and sentenced him to death, ordering civil indemnities. The case was automatically brought to the Supreme Court for review.
Issues on Appeal
- Whether the uncounselled confession and related pointing out of the body violated the accused’s rights under Article III, Section 12 of the 1987 Constitution and are therefore inadmissible.
- Whether the circumstantial evidence (slippers, T-shirt, presence at crime scene) proved guilt beyond reasonable doubt.
Supreme Court’s Analysis
- Admissibility of Confession and Derivative Evidence
- The accused was arrested without being informed of his rights to remain silent and to counsel; no written waiver was obtained.
- Article III, Section 12 of the 1987 Constitution prohibits the admission of any confession obtained in violation of these rights.
- The pointing-out of the body was an integral part of the uncounselled confession and thus is fruit of the poisonous tree.
- The Vice-Mayor’s testimony reflected only ambiguous responses by Lugod, not a clear admission of rape and homicide. Contradictions and the coercive atmosphere (presence of police and hostile townspeople, allegations of maltreatment) also undermined voluntariness.
- Confession and pointing-out evidence were ruled inadmissible.
- Sufficiency of Circumstantial Evidence
- Under Rule 133, Section 4, circumstantial evidence must form an unbroken chain leading to guilt to the exclusion of all reasonable hypotheses.
- The slippers and T-shirt were ordinary articles without unique identifying marks; their presence at the scene established only
Case Syllabus (G.R. No. 164749)
Facts of the Case
- On the night of September 15, 1997, eight-year-old Nairube J. Ramos disappeared from her home in Cavinti, Laguna.
- At around 12:30 a.m., her parents sensed someone descending their stairs; upon investigation, they discovered the backdoor ajar and Nairube missing.
- Search parties discovered her blood-stained panty and a black collared T-shirt within Villa Anastacia plantation.
- On September 18, 1997, the accused, Clemente John Lugod, pointed out the location of the victim’s body inside a grassy coconut plantation, approximately 200 meters from the road.
- Medico-legal examination on September 19, 1997 revealed an 8 cm vaginal laceration and death by hypovolemic shock secondary to vulvar laceration.
Charges and Plea
- October 10, 1997: Information filed for rape with homicide under Section 11 of Republic Act No. 7659.
- Accused charged with willfully, unlawfully, and feloniously having carnal knowledge of an eight-year-old girl by force and intimidation, then dumping her to conceal the crime, causing her death.
- Upon arraignment, the accused pleaded not guilty.
Trial Proceedings
- Regional Trial Court of Santa Cruz, Laguna, Branch 28 (Criminal Case No. SC-6670).
- Prosecution presented over a dozen witnesses, including medico-legal officers, barangay tanods, neighbors, family members, and police officers.
- Defense advanced denial and alibi; accused did not testify.
Prosecution Evidence
- Medico-Legal Officer (Dr. Edilberto Castillo): cadaver in advanced decomposition; 8 cm vaginal wound; estimated death three days prior; cause hypovolemic shock.
- Witnesses (Violeta Cabuhat, Loreto Veloria, Pedro Dela To