Title
People vs. Lugod
Case
G.R. No. 136253
Decision Date
Feb 21, 2001
An 8-year-old girl was raped and killed in 1997. The accused, Clemente John Lugod, was convicted based on circumstantial evidence and an alleged coerced confession. The Supreme Court acquitted him, citing insufficient proof and constitutional rights violations.

Case Summary (G.R. No. 136253)

Procedural History

An Information for rape with homicide was filed against the accused on October 10, 1997. After arraignment and trial, the RTC of Santa Cruz, Laguna (Branch 28) found Lugod guilty beyond reasonable doubt and sentenced him to death, with orders for civil indemnity and actual damages. Because the death penalty was imposed, the case came to the Supreme Court on automatic review. The accused appealed, assigning errors mainly concerning the sufficiency of circumstantial evidence and the alleged confession.

Facts as Established at Trial

Prosecution witnesses testified that Lugod was seen on the evening of September 15, 1997 wearing a black collared T-shirt and a distinctive pair of rubber slippers (muddy sole red, top yellow). The slippers were later found near the victim’s backdoor, and a black T-shirt was found hung on a twig near where the victim’s body was discovered inside Villa Anastacia. Witnesses also testified that Lugod had been drinking that night, entered another house without consent, and was seen coming out of Villa Anastacia the morning after without slippers and without a T‑shirt. The medical examiner testified to an 8 cm vaginal wound, advanced decomposition, and cause of death as hypovolemic shock secondary to laceration. Police testimony recounted that Lugod initially denied involvement but later allegedly admitted to SPO2 Gallardo and supposedly pointed out the body’s location; the latter acts were testified to as having occurred while Lugod was under police custody.

Trial Court Findings and Sentence

The RTC relied on the combination of circumstantial evidence (presence of slippers and T‑shirt linked to Lugod, eyewitness sightings of Lugod at and around Villa Anastacia, Lugod’s pointing out of the cadaver’s location, and purported confessions) and eyewitness identifications to convict Lugod of rape with homicide and impose the death penalty. The court ordered indemnity of P50,000 and actual damages of P37,200 for the heirs.

Assignments of Error on Appeal

The accused-appellant challenged conviction on two principal grounds: (1) the prosecution relied on circumstantial evidence that did not prove guilt beyond reasonable doubt; and (2) the trial court erred in admitting and relying upon an alleged confession to local officials (Mayor and Vice‑Mayor) and inculpatory statements made to police, which were argued to be inadmissible.

Constitutional and Evidentiary Standards Applied

Because the decision date is after 1990, the Court applied the 1987 Constitution. Article III, Section 12 of the 1987 Constitution (as quoted in the record) guarantees that a person under investigation must be informed of rights to remain silent and to counsel; any waiver must be in writing and in the presence of counsel; torture, force, or intimidation are prohibited; and confessions obtained in violation of these protections are inadmissible. For circumstantial evidence, the Court applied Rule 133, Section 4 of the Rules on Evidence: circumstantial evidence suffices for conviction only when (a) there is more than one circumstance; (b) the facts from which inferences are drawn are proven; and (c) the combination of circumstances produces conviction beyond reasonable doubt. The Court reiterated that circumstantial evidence must form an unbroken chain pointing to the accused to the exclusion of others.

Analysis of the Alleged Confession and Pointing Out

The Supreme Court found that at the time of his apprehension Lugod was not informed of his constitutional rights and no valid written waiver with counsel was shown. Consequently, any admission to SPO2 Gallardo or statements made while in custody could not be admitted against him. The Court treated Lugod’s alleged pointing out of the body as an integral part (fruit) of the uncounselled confession and therefore inadmissible under the poisonous tree doctrine. The Court further considered the conditions of Lugod’s detention—presence of police and a hostile crowd during the pointing out, and allegations of physical maltreatment—as factors undermining voluntariness. The Vice‑Mayor’s testimony, offered as evidence of a confession to municipal officials, was held not to support a categorical confession: the Vice‑Mayor’s questions were ambiguous, Lugod’s answers were equivocal (he said he was very drunk and did not recall), and the Vice‑Mayor expressly testified that Lugod did not say he raped and killed the victim. The Court noted contradictory testimony about who was present and the content of the alleged confession. Because the alleged confession was inadmissible or unproven, the Court excluded it from the evidentiary basis.

Analysis of Circumstantial Evidence (Slippers, T‑shirt, Sightings)

With the confession and pointing‑out excluded, the remaining evidence was primarily circumstantial: eyewitness identifications of Lugod as the person observed wearing the slippers and T‑shirt; discovery of those items near the victim’s premises and near where the body was found; testimony that Lugod was seen at Villa Anastacia in the early morning without slippers and T‑shirt. The Supreme Court emphasized that such circumstances, even collectively, established only Lugod’s presence at or near the scene at relevant times and did not positively connect him to the actual rape and killing. The Court observed that the slippers were common, undistinguished items; precedent shows such ordinary items do not nece

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