Case Summary (G.R. No. 218210)
Chronology of Events
On November 12, 2003, at approximately 5:00 PM, the victim AAA expressed a desire to accompany Villegas to visit a friend, which her mother BBB did not allow. Despite this, AAA left the house. Witness Felicidad Bornales observed AAA and Villegas talking near a water pump around 5:30 PM. Later that night, concerns arose when AAA did not return home. AAA's body was discovered in a pond later, prompting the family to report the incident to the authorities. Villegas surrendered to the police on November 14, 2003.
Charges and Proceedings
An Information accusing Villegas of rape with homicide was filed on April 28, 2004. Villegas entered a plea of not guilty. The trial revealed crucial evidence, including testimonies from eyewitnesses and medical findings. The attending medico-legal officer found AAA had suffered intracranial hemorrhage and had recently lost her virginity, linking Villegas to the crime.
Ruling of the Regional Trial Court (RTC)
The RTC found sufficient circumstantial evidence to convict Villegas beyond reasonable doubt, noting the following:
- Villegas and AAA's rapport made it plausible for him to lure her.
- Bloodstains and personal items linked to both the victim and Villegas were found in the abandoned house where the crime likely took place.
- Villegas was the last person seen with AAA before her disappearance.
Consequently, the RTC sentenced Villegas to reclusion perpetua and ordered him to pay monetary damages to AAA's heirs.
Appeal to the Court of Appeals (CA)
Dissatisfied with the RTC's ruling, Villegas appealed, arguing the trial court relied too heavily on circumstantial evidence and did not adequately consider his alibi. The CA examined the circumstantial evidence, such as witness accounts and physical evidence found at the crime scene, concluding that these circumstances collectively pointed to Villegas as the perpetrator. It emphasized that alibi defenses must demonstrate physical impossibility for the accused's absence from the crime scene, which Villegas' defense did not convincingly establish.
Decision of the Court of Appeals
The CA upheld the RTC's ruling, affirming Villegas' conviction while modifying the penalties to exclude parole eligibility and adjusting the monetary damages to be awarded to the victim's heirs.
Supreme Court's Evaluation
In his appeal to the Supreme Court, Villegas contested the sufficiency of circumstantial evidence and inconsistencies in witness testimonies. The Court noted that circumstantial evidence ca
...continue readingCase Syllabus (G.R. No. 218210)
Background of the Case
- The appeal concerns a conviction for rape with homicide against Noli Villegas, Jr. y Lacrete, rendered by the Regional Trial Court (RTC) of Barotac Viejo, Iloilo.
- The case arose from events occurring on November 12, 2003, where the victim, referred to as AAA, was last seen in the company of the accused.
- The RTC's decision was affirmed by the Court of Appeals (CA) on September 24, 2014, prompting the appeal.
Antecedents of the Crime
- On the day of the incident, AAA sought permission from her mother, BBB, to accompany Villegas to visit a friend, which was denied.
- Despite this, AAA was later seen with Villegas by a witness, Felicidad Bornales, who overheard Villegas inviting AAA to accompany him to a nearby mountain, which she declined.
- By 8 PM that evening, BBB became concerned about AAA's absence and began searching for her with the help of neighbors.
- Evidence of AAA's presence was discovered in an abandoned house, including a white T-shirt, slippers, and bloodstains, leading to the report of AAA's disappearance to local authorities.
Discovery of the Victim
- On November 14, 2003, AAA's body was found in a pond in a rice field, prompting a medico-legal examination that indicated death due to intracranial hemorrhage from a traumatic head injury.
- The prosecution established that AAA had susta