Case Summary (G.R. No. 219185)
Key Dates
Offense and disappearance: July 2, 1999.
Body discovered and related police activity: July 3, 1999.
Information filed with RTC (Caloocan City, Branch 128): July 7, 1999.
Arraignment: August 19, 1999.
RTC conviction: May 27, 2004.
Court of Appeals decision (affirming with modification): February 22, 2007.
Supreme Court decision under review: April 11, 2012.
Applicable Law and Constitutional Basis
Applicable constitution: 1987 Philippine Constitution (decision rendered after 1990).
Statutes and rules relied on in the proceedings: Republic Act No. 8353 (Anti-Rape Law of 1997), Republic Act No. 9346 (abolishing death penalty and commuting certain sentences), Article 48 of the Revised Penal Code (complex/compound crimes), Sections of the Civil Code governing damages (Articles 2229 and 2230), Act No. 4103 (Indeterminate Sentence Law) as affected by RA 9346, and Section 4, Rule 133 of the Rules of Court governing circumstantial evidence. The case also applies established jurisprudential standards on composite crimes and the proper appreciation of circumstantial evidence.
Procedural History
The City Prosecutor filed an information charging Villaflores with rape with homicide. Villaflores pleaded not guilty and was tried in the Regional Trial Court (Branch 128), which convicted him of rape with homicide and imposed the death penalty plus civil liabilities. On intermediate appeal, the Court of Appeals affirmed the conviction but modified the penalty, commuting the death sentence to reclusion perpetua and adjusting damages. The Supreme Court reviewed the case on automatic review, sustained the conviction, further specified the penalty consequences under RA 9346 (including ineligibility for parole), added exemplary damages, and ordered interest on all awards.
Facts Established at Trial (Material and Uncontested for Purposes of the Decision)
- The child, Marita, went missing on July 2, 1999 after being observed playing at the rear of her home. Her parents searched from noon until late evening and reported her missing to police the next morning.
- Following a clairvoyant’s direction, the parents located the child’s lifeless body in the comfort room of an abandoned house about five houses away. The body was covered with a blue sack; a yellow sack was under her head; a white nylon rope was around her neck. The face and body bore multiple injuries and blood.
- Two neighborhood witnesses, Aldrin Bautista and Jovy/Jovie Solidum, testified that on July 2, 1999 they saw Villaflores leading the child by the hand in the morning; Solidum heard a child crying in Villaflores’s house at about 3:00 p.m.; Solidum later saw Villaflores carrying a yellow sack toward the vacant house at about 7:00 p.m. that evening.
- Physical evidence recovered at the scene included a nylon cord (Exhibit N) and a yellow sack; the yellow sack and rope were later linked to Villaflores’s premises (the rope resembling one tied to Villaflores’s door and the yellow sack used as wall-covering for his toilet).
- Medico-legal findings (autopsy by Dr. Marquez) showed multiple head and body injuries, a congested and lacerated genital area with multiple deep fresh hymenal lacerations, vaginal and periurethral smears positive for spermatozoa, and a ligature mark consistent with strangulation; cause of death was asphyxia by strangulation. The body was in the secondary stage of flaccidity at the time of examination, consistent with death occurring more than 24 hours earlier.
- Villaflores denied the accusations and asserted an alibi that he was in Phase 10 at the market obtaining plywood for his aunt between approximately 8:30 a.m. and 5:00 p.m. on July 2, 1999. He admitted drug use and association with the eyewitnesses. A defense witness (Sherwin Borcillo) initially sought to exculpate the accused by alleging that other individuals placed and moved the sack, but under cross-examination Borcillo’s familial relationship to Villaflores and inconsistencies undermined his credibility.
Issues Presented for Resolution
- Whether the State proved beyond reasonable doubt that Villaflores committed rape with homicide.
- Whether circumstantial evidence was sufficient to establish both the commission of the crime and the identity of the perpetrator.
- Whether the trial court and appellate court properly assessed and weighed exculpatory defense evidence and alibi testimony.
Legal Characterization: Rape with Homicide as a Composite Crime
The Court reiterated that rape with homicide is a composite (special complex) crime: two or more distinct offenses combined by statute into a single, indivisible offense punishable by a specific penalty. Under RA 8353 the law defines rape (including statutory rape where the victim is under twelve years) and prescribes aggravated/qualifying circumstances; Article 266-B provides that when rape is consummated and homicide is committed by reason of or on the occasion of the rape, a specific, single penalty applies. The Court differentiated composite crimes from Article 48 complex/compound crimes, noting that in composite crimes the combination is fixed by law and the single prescribed penalty governs.
Standards for Circumstantial Evidence and Their Application
The Supreme Court reiterated the established test for circumstantial evidence: (a) there must be more than one circumstance; (b) the primary facts from which inferences are drawn must be proved; and (c) the combined circumstances must produce conviction beyond reasonable doubt (Section 4, Rule 133). The Court applied the classic standard that the proven circumstances, when taken together, must be consistent with guilt and inconsistent with every reasonable hypothesis of innocence. The Court emphasized that circumstantial evidence is admissible to prove both the occurrence of the crime and the perpetrator’s identity and that no higher degree of certainty is required for circumstantial than for direct evidence.
The Court’s Findings on Elements of the Crime — Carnal Knowledge, Lack of Consent, and Death by Reason/On the Occasion of Rape
- Carnal knowledge and absence of consent: Under Article 266-A, carnal knowledge of a female under twelve constitutes rape per se (statutory rape). The medico-legal findings demonstrated multiple deep fresh hymenal lacerations and positive smears for spermatozoa; the autopsy opinion attributed the injuries to insertion of a blunt object consistent with a human penis. These results satisfied the element of carnal knowledge and, given the victim’s tender age, lack of consent was legally presumed.
- Homicide by reason of or on the occasion of the rape: The autopsy established asphyxia by strangulation as cause of death with ligature marks consistent with the rope found. The temporal and circumstantial evidence (testimony locating Villaflores with the child earlier, the crying heard from his house in the afternoon, the sighting of him carrying a heavy yellow sack toward the abandoned house at about 7:00 p.m., and the medico-legal estimation of time of death) linked the killing in time and circumstance to the rape, satisfying the composite crime’s requirement that the homicide be by reason of or on the occasion of the rape.
Sufficiency of Circumstances Linking Villaflores to the Crime (Identity and Guilt)
The Court identified and considered a series of interlocking circumstances: eyewitness observations of Villaflores leading the child by the hand; the child’s disappearance thereafter; hearing of the child’s cries emanating from Villaflores’s premises; seeing Villaflores carry a heavy yellow sack toward the location where the body was found; identification of the yellow sack and the white rope at the crime scene as traceable to Villaflores’s house; Villaflores’s familiarity and access to the abandoned house (rear exit and hidden pathway); the medico-legal evidence of sexual assault and strangulation; and the postmortem timing of death consistent with the eyewitness timeline. The Court concluded these circumstances formed an unbroken chain, consistent only with Villaflores’s guilt and inconsistent with reasonable alternative hypotheses.
Assessment of Defense Evidence and Alibi; Credibility Determinations
The Court found the defense alibi unsupported and the proffered exculpatory testimony unreliable. The alibi lacked corroboration: the aunt alleged to have called and received plywood did not substantiate the alibi, and the defense did not demonstrate phy
Case Syllabus (G.R. No. 219185)
Procedural History
- Case originated in the Regional Trial Court (RTC), Branch 128, Caloocan City; accused Edmundo Villaflores was convicted of rape with homicide by RTC on May 27, 2004.
- The Court of Appeals (CA) affirmed the conviction with modification on February 22, 2007, commuting the death penalty to reclusion perpetua and adjusting civil awards.
- The case was the subject of automatic review by the Supreme Court; final decision promulgated April 11, 2012 (G.R. No. 184926).
- Key pretrial/pleading dates: arrest July 3, 1999; information filed July 7, 1999; arraignment August 19, 1999.
- The Supreme Court affirmed the conviction with specific modifications and additional awards; it ordered reclusion perpetua without eligibility for parole and added exemplary damages.
Parties and Identities
- Plaintiff-Appellee: People of the Philippines.
- Accused-Appellant: Edmundo Villaflores y Olano (referred to in the record by the neighborhood tag "Batman").
- Victim: "Marita" (fictitious name used pursuant to R.A. No. 7610 and R.A. No. 9262); real name withheld.
- Victim’s parents referenced: Julia (mother) and Manito (father). Fictitious names used in record.
Relevant Dates and Basic Chronology
- Victim’s birth: Certificate of Live Birth marked Exhibit K indicates October 29, 1994 (alternate reference in CA summary cites October 21, 1994).
- Date of disappearance and alleged offense: July 2, 1999.
- Discovery of lifeless body: morning of July 3, 1999 (found by family following clairvoyant’s direction); medico-legal autopsy conducted July 3, 1999 at about 8:00 p.m.
- Arrest of accused: around 5:00 p.m., July 3, 1999.
- Information filed by City Prosecutor of Caloocan City: July 7, 1999.
- RTC conviction: May 27, 2004. CA decision: February 22, 2007. Supreme Court decision: April 11, 2012.
Facts as Found in the Record (Overview)
- Morning of July 2, 1999: Marita was playing at the rear of her residence in Bagong Silang, Caloocan City; Julia first noticed Marita missing.
- Noontime July 2, 1999: Marita remained missing; Julia phoned husband Manito at his workplace in Pasig City; Manito rushed home (arrived ~2:00 p.m.) and searched with Julia until about 11:00 p.m.
- July 3, 1999, 6:00 a.m.: Manito reported Marita missing to police.
- In desperation, Julia consulted a clairvoyant who directed them to look five houses away; they found Marita’s lifeless body inside the comfort room of an abandoned house, covered with a blue and yellow sack.
- Condition of body: face black and blue, bloody; tortured and strangled to death; yellow sack under her head; blue sack covering body; white nylon cord around neck.
Discovery of the Victim and Crime Scene Details
- Location where body found: comfort room of an abandoned/unoccupied house about five structures away from victim’s house (Phase 9, Bagong Silang, Caloocan City).
- Items recovered at scene: yellow sack (found behind victim's head), blue sack (used to cover victim’s face/body), white nylon cord/rope around the neck (Exhibit N).
- Observations by first responders and SOCO: victim’s face black and blue, blood stains on lips, blood staining in the vagina, yellow sack showing greenish and fleshy coloring when exhibited in court; photographs taken (Exhibits R, S, T referenced).
Arrest, Investigation, and Statements
- Two neighborhood witnesses, Aldrin Bautista and Jovie (Jovy) Solidum, identified Villaflores as a person of interest and later testified they saw Villaflores leading Marita by the hand on July 2, 1999.
- Arrest of Villaflores occurred on July 3, 1999, as he alighted from a vehicle near the police precinct; he was taken to Sub-station 6.
- Statements and affidavits:
- Father Manito’s statements and funeral expense receipts (Exhibit L, Exhibit M).
- Wife of accused, Erlinda Villaflores, gave a sworn statement (Exhibit X and sub-markings) admitting she saw sacks under the house and later saw a protruding elbow in a sack.
- Statements of Aldrin Bautista marked in the record; confrontation conducted where Aldrin identified Villaflores in detention.
- SOCO and police officers prepared initial reports, sketches, and reports (Exhibits U, V, W and sub-markings).
Prosecution’s Witnesses and Key Testimony (State Evidence)
- Aldrin Bautista and Jovie (Jovy) Solidum:
- Testified they saw Villaflores leading Marita by the hand at about 10:00 a.m., July 2, 1999.
- Jovie testified he heard a child crying at about 3:00 p.m. when passing the accused’s house, and later at about 7:00 p.m. saw Villaflores carrying a yellow sack appearing heavy toward the vacant/abandoned house.
- Both witnesses admitted to drug use (shabu); Aldrin had a "sputnik" tattoo; Jovie belonged to the T.C.G.
- Manito (father of victim):
- Kept searching for his daughter; identified the yellow sack covering his daughter’s head and recalled a blue sack covering the body; incurred funeral expenses (Exhibit L).
- SPO2 Protacio Magtajas, SPO2 Arsenio Nacis, PO3 Rodelio Ortiz, PO Harold Blanco, PO Sonny Boy Tepase:
- Investigative officers who secured scene, recovered evidence (yellow sack, nylon rope), took statements, prepared referrals, and assisted in arrest.
- SOCO Team (Inspector Abraham Pelotin as team leader) and NBI/PNP Crime Laboratory personnel:
- Photographed the scene and victim; prepared SOCO reports and sketches (Exhibits S,T,R, U,V,W); marked and tagged evidence.
- Dr. Jose Arnel Marquez, Medico-Legal Officer:
- Conducted autopsy July 3, 1999; prepared Medico Legal Report No. M-250-99 (Exhibit H) and death certificate (Exhibit E); anatomical and head sketches (Exhibits I and J).
Medico-Legal Findings (Detailed)
- General condition: fairly developed, fairly nourished female child cadaver; secondary stage of flaccidity with postmortem lividity at dependent portions; conjunctivae pale; lips and nailbeds cyanotic.
- Head, neck and trunk injuries (as detailed in postmortem findings):
- Hematoma, right periorbital region, 4 x 3.5 cm.
- Multiple abrasions, right zygomatic region, 4 x 2.2 cm.
- Abrasion, right cheek, 1.7 x 0.8 cm.
- Multiple abrasions, upper lip, 4 x 1 cm.
- Contusion, frontal region, 6 x 4 cm.
- Punctured wound, left pre-auricular region, 9.2 x 0.1 cm.
- Ligature mark on neck, 24 x 0.5 cm, bisected by anterior midline.
- Abrasions on right and left scapular regions.
- Genital/sexual injuries:
- Multiple deep fresh lacerations at the hymen; vestibule abraded and markedly congested; posterior fourchette lacerated and markedly congested.
- Vaginal and periurethral smears tested positive for spermatozoa.
- Medico-legal opinion: multiple lacerations could have been caused by insertion of a blunt object such as a human penis; smears positive for spermatozoa confirmed adult human penis as blunt object.
- Internal findings:
- Lining mucosa of larynx, trachea and esophagus markedly congested with scattered petechial hemorrhages.
- Stomach about half full of partially digested food (mostly rice).
- Cause of death:
- Asphyxia by strangulation (ligature strangulation) — "asphyxia by strangulation" indicated as cause of death.
- Time of death estimation:
- Victim already dead for 24 hours at time of autopsy (July 3, 1999, ~8:00 p.m.); body in second stage of flaccidity consistent with death occurring at the latest by 9:00 p.m. of July 2, 1999; medico-legal consideration that victim could have been dead at least by 9:00 a.m. on July 2 (discussion of stages of flaccidity and rigor mortis).
- Possible causes of external injuries:
- Blunt instrument contact (e.g., piece of wood) and contact with hard, rough surfaces; punctured wounds possibly caused by a pointed object (e.g., barbecue stick).
Defense Evidence and Accused’s Testimony
- Edmundo Villaflores’ testimony:
- Denied seeing the child on July 2, 1999; claimed he was at Phase 10 market around 10:00 a.m. obtaining plywood for his Aunt Maring (alibi that he ran an errand for his aunt at ~8:30 a.m. and stayed for ~5 hours, returning home around 5:00 p.m.).
- Acknowledged being known as "Batman" and admitted acquaintance with Aldrin and Jovie who were neighbors and who used shabu at his house.
- Denied carrying or throwing a sack to the vacant lot, denied knowledge of reason for arrest; listed potential witnesses (Maring, Sherwin, Pareng Bong, Frankie) to corroborate absence.
- On cross-examination admitted drug use in company of friends; admitted Aldrin and Jovie harbored ill feelings because he had not allowed their drug use; denied that the door of his house had a sack covering or that it was locked by a string.
- Sherwin Borcillo (neighbor/electronic technician and nephew of accused):
- Testified that on the night of July 2 he saw Aldrin, Jovie and another person (Jose Pitallana) at the back of Villaflores’ house carrying a sack which they later left near the comfort room outside accused’s house; he claimed they offered a dog in the sack to the accused and later took the yellow sack away.
- Executed an affidavit/Salaysaya at the purok after accused’s arrest and