Case Summary (G.R. No. 150224)
Factual Background
On June 30, 1998, appellant lurked in his mother-in-law’s house where Kathylyn Uba, his wife’s cousin, was alone. Witnesses saw him entering the ground floor kitchen and pacing outside. In the evening, Isabel Dawang discovered Kathylyn’s naked, stabbed body on the second floor, intestines exposed and personal garments scattered.
Direct Witness Accounts
Judilyn Pas-a testified to seeing appellant descend via ladder at 12:30 p.m. and reappear at 1:30 p.m. wearing a different shirt, eyes reddish, then hurriedly depart upon her husband’s arrival. Anita Wania and Beverly Deneng observed him near the kitchen at 10 a.m., claiming to fetch lumber. Neighbors corroborated his presence around the time of death.
Forensic Findings on Time of Death
Dr. Pej Evan C. Bartolo noted complete rigor mortis at 9 a.m. on July 1, placing death between 9 a.m. and 12 p.m. on June 30. Eleven abdominal and back wounds were documented, consistent with homicidal stabbing.
Evidence of Sexual Assault and Resistance
The postmortem revealed semen in the vaginal canal despite intact hymen; a bruise and swelling on the victim’s right forearm indicated struggle against force.
DNA Profiling and Expert Testimony
Dr. Ma. Corazon de Ungria of UP-NSRI, qualified as DNA expert, applied PCR-STR analysis to semen slides and appellant’s blood sample taken in open court. The gene types (vWA 15/19; TH01 7/8; D7S820 9/10; CSF1PO 10/11) matched identically, establishing appellant as the semen source.
Admissibility and Reliability of DNA Evidence
Under the 1987 Constitution and Rules of Court, DNA results are relevant and reliable when proper chain of custody, contamination safeguards, analytical procedures, and qualified analysts are demonstrated. By analogy to Daubert (U.S.), the PCR-STR method satisfies scientific validity and judicial scrutiny.
Circumstantial Evidence and Flight
Beyond DNA, thirteen circumstantial factors—appellant’s cohabitation, receipt of a letter via victim, his changing attire, door rope barring, bloodied shirt, semen presence, and his escape and recapture—formed an unbroken chain excluding others and indicating guilt.
Defense Contentions and Rejection
Appellant invoked right against self-incrimination to exclude DNA sampling and raised ex post facto objections. The Court distinguished physical evidence (non-testimonial) from compelled admissions, citing People v. Rondero and Gallarde. No ex post facto issue arises because DNA profiling pertains to evidence admissibility, not substantive law retroactivity.
Alibi and Motive
Appellant’s denial and alibi failed: he lived within 100 meters of the crime scene, no impossibility proven. Motive was shown by victim’s testimony of a prior rape attempt by appellant and his threat to kill the family upon spouse’s separation. Motive evidence aligns with established criminal jurisprudence.
Standard of Proof and Moral Certainty
Conviction required proof beyond reasonable doubt—moral certainty. The totality of direct, forensic, DNA, circumstantial, and motive evidence satisfied that standard, establishing that appellant alone committed the rape with homicide.
Elements of Rape with Homicide
(1) Carnal knowledge of a woman by force; (2) accomplishme
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Facts
- On June 30, 1998, Kathylyn D. Uba and her cousin Judilyn Pas-a were at their grandmother Isabel Dawang’s house in Liwan West, Rizal, Kalinga.
- Early that morning, Kathylyn delivered a letter from Luz Yatar to appellant Joel Yatar.
- Judilyn and her husband left for their farm at 9:00 a.m., leaving Kathylyn alone. Kathylyn expressed plans to travel or wash clothes.
- Around 10:00 a.m., Anita Wania and Beverly Deneng saw appellant behind the house, claiming to gather lumber.
- Judilyn observed appellant descending the second-floor ladder at 12:30 p.m., pacing at the back of the house, and again at 1:30 p.m. wearing different clothes.
- In the evening, Isabel found Kathylyn’s door tied and, in the dark, discovered the victim’s naked, cold, and rigid body with intestines protruding.
- Neighbors and police arrived; the scene revealed multiple stab wounds, scattered clothing, and a blood-stained shirt 50 meters away.
Procedural History
- Joel Yatar was charged with Rape with Homicide under Article 266-A of the Revised Penal Code, as amended by R.A. 8353.
- He pleaded not guilty at arraignment on July 21, 1998.
- The Regional Trial Court of Bulanao, Tabuk, Kalinga, Branch 25, convicted him and sentenced him to death.
- The trial court also ordered payment of civil indemnity (₱75,000), moral damages (₱200,000), exemplary damages (₱50,000), actual damages (₱186,410), and litigation costs.
- This case proceeded on automatic review pursuant to Article 47 of the Revised Penal Code, as amended.
Issues on Appeal
- Whether the trial court gave undue weight to doubtful prosecution evidence.
- Whether there existed reasonable doubt warranting acquittal.
Trial Court’s Credibility Findings
- The trial court’s evaluation of witness credibility enjoys great weight absent overlooked facts or misinterpretations.
- No evidence showed improper motive or testimony bias among prosecution witnesses.
- Credibility assessments by the trial judge, wh