Case Summary (G.R. No. 152411)
Antecedents
On March 26, 2002, AAA was instructed by her parents to collect payment for rice cakes from Milo. While AAA's siblings returned home, she did not. After a night of searching, her parents reported her missing, only to later be informed by barangay officials that her body had been found in Milo's house. An autopsy revealed that AAA died from asphyxia due to suffocation. Furthermore, her body exhibited extensive injuries, including multiple abrasions and injuries consistent with sexual assault. Consequently, Milo was charged with the complex crime of rape with homicide.
Trial Proceedings
During the trial, Milo pleaded not guilty but admitted to killing AAA, asserting it was accidental. He claimed an abrupt awakening led to an unconscious punch that accidentally killed her. The Regional Trial Court (RTC) found sufficient circumstantial evidence to convict Milo and sentenced him to reclusion perpetua, alongside monetary compensation to AAA's heirs.
Appeal to the Court of Appeals
Milo appealed the RTC's decision, disputing the credibility of witness testimony and claiming the absence of sufficient circumstantial evidence. In its September 15, 2015 ruling, the Court of Appeals upheld the RTC's decision, citing the evidence that convincingly pointed to Milo's guilt.
Legal Principles Involved
The ruling emphasized that the prosecution must establish beyond a reasonable doubt the elements of rape and homicide when charged complexly. Notably, Milo's admission to killing AAA, even if claimed to be accidental, does not absolve him of criminal liability under the Revised Penal Code's provisions regarding intent and culpability.
Assessment of Accident Defense
The court rejected Milo's defense of accident, stating that the act of boxing AAA constituted unlawful and negligent behavior. The circumstances surrounding AAA's death and the injuries she sustained indicated intent to kill, undermining Milo's assertions of the act being an accident.
Circumstantial Evidence
The court outlined that in the absence of direct testimony regarding the rape, the combination of circumstances linked to the crime—AAA's last known location at Milo's house, the discovery of her body there, and the medical findings of violence and sexual assault—created a compelling and unbroken chain of evidence supporting the prosecution's case.
Conclusion on Appeal
The Supreme Court ultimately dismissed Milo's appeal. It affirmed the previous rulings along with penalties, reiterating the necessity of strict adherence to evidentiary standards in sexual assault and homicide cases. Furthermore, the court modified mo
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Case Background and Facts
- On March 26, 2002, AAA227396, a 12-year-old girl, was sent by her parents to collect payment from their neighbor, Milo Leocadio y Labrador.
- AAA227396 went missing and was found dead the next day in Milo's house.
- The victim was found under Milo's wooden bed with her mouth and nose covered, hands tied behind her back.
- Autopsy showed death by asphyxia due to suffocation.
- The victim sustained hymenal lacerations and 33 injuries across various parts of her body, indicating sexual assault and physical abuse.
- Milo was charged with the complex crime of rape with homicide.
Charges and Plea
- Milo was charged before the Regional Trial Court (RTC) of Romblon with rape with homicide.
- Milo pled not guilty but admitted to the killing, claiming it was accidental.
- He denied the rape allegation.
Trial Court Decision
- The RTC found Milo guilty beyond reasonable doubt based on circumstantial evidence.
- The autopsy and witness testimonies, particularly that of the victim's father, were credited.
- Milo was sentenced to reclusion perpetua without parole and ordered to pay civil indemnity, moral damages, exemplary damages, and temperate damages.
Appeal to the Court of Appeals
- Milo appealed, arguing the testimonies were incredible and circumstantial evidence insufficient.
- He reiterated his claim of accidental killing and denial of rape.
- The CA affirmed the RTC decision with modification by imposing interest on damages.
- The CA highlighted the strong chain of circumstantial evidence linking Milo to the crime:
- The victim was last sent to Milo's house.
- The victim was missing until found dead in Milo's house.
- Milo admitted the victim was present and that he hit her.
- Medical findings supported suffocation and multiple injuries inconsistent with an accidental single punch.
- Hymenal lacerations with presence of dried blood indicated rape.
Supreme Court's Ruling and Reasoning
- The appeal filed by Milo was dismissed; the conviction was upheld.
- The Court recognized the difficulty in prosecuting rape and rape with