Case Summary (G.R. No. 119172)
Petitioner
People of the Philippines
Respondent
ZZZ
Key Dates
• May 16, 1996 – Incident occurred
• February 6, 2003 – Arrest of ZZZ
• March 4, 2013 – RTC conviction
• February 29, 2016 – CA affirmed
• July 24, 2019 – SC decision
Applicable Law
• 1987 Constitution of the Philippines
• Revised Penal Code Arts. 266-A (rape), 266-B (penalties), 63 (indivisible penalties), 68(2) (minority)
• Republic Act No. 9344 (Juvenile Justice and Welfare Act)
• Rules on Evidence, Rule 133 § 4 (circumstantial evidence)
Factual Background
On the evening of May 16, 1996, BBB saw ZZZ dragging AAA by the wrist toward a schoolyard. The next day AAA was reported missing. A few days later, barangay officials found her decomposed, naked body in a bamboo grove, with a cracked temporal skull and a half-inch laceration below the left labia. ZZZ left town, assumed an alias in Tarlac, and was arrested in 2003.
Trial Court Proceedings
ZZZ was charged with rape with homicide. Prosecution presented BBB’s identification, police testimony recounting his flight and brother YYY’s initial statement, and autopsy findings by Drs. Mejia and Bandonill confirming cranial trauma and genital injury. Defense offered ZZZ’s alibi—he watched television at his grandmother’s with YYY and AAA—and YYY’s recanted alibi. The RTC found circumstantial evidence unbroken, convicted ZZZ beyond reasonable doubt, suspended the sentence under RA 9344, and awarded damages.
Court of Appeals Ruling
The CA upheld conviction: (1) BBB’s testimony was credible and spontaneous; (2) circumstantial evidence—last seen with victim, flight, alias—met Rule 133 requirements; (3) ZZZ acted with discernment under RA 9344, hence not exempt; (4) suspension of sentence inapplicable due to age at conviction; and (5) damages affirmed.
Issues on Appeal
- Whether guilt for rape with homicide was proven beyond reasonable doubt
- Whether ZZZ acted with discernment, negating exemption under RA 9344
Supreme Court’s Analysis – Circumstantial Evidence
The SC applied Rule 133 § 4: multiple proven facts—BBB’s sighting, YYY’s statements, flight and alias, autopsy findings—produced moral certainty of guilt. Direct evidence being absent in rape cases, the unbroken chain of inferences sufficed for conviction.
Witness Credibility and Alibi
The SC deferred to the RTC’s credibility findings. BBB had no motive to falsely implicate. YYY’s retraction and inconsistency undermined the alibi. ZZZ’s challenge that suspicion alone was insufficient failed; he did not establish physical impossibility of presence at the crime scene.
Discernment under RA 9344
RA 9344 exempts children 15–18 absent discernment. The SC found ZZZ displayed discernment by committing the crime in isolation, evading arrest, and understanding consequences (as confirmed by a social worker). Thus he was subject to criminal proceedings.
Penalties and Damages
Under R
Case Syllabus (G.R. No. 119172)
Procedural Posture
- Appeal from the Court of Appeals’ February 29, 2016 Decision in CA-G.R. CR-HC No. 06486 affirming the RTC’s March 4, 2013 Decision in Criminal Case No. SCC-2594.
- ZZZ was charged by Information dated October 14, 1996 with the special complex crime of rape with homicide.
- Accused pleaded not guilty; trial court convicted him beyond reasonable doubt; sentence and damages suspended and modified under RA 9344.
- Court of Appeals denied the appeal; case elevated to the Supreme Court, which required supplemental briefs.
Facts of the Case
- On the evening of May 16, 1996, BBB saw ZZZ dragging his eleven-year-old cousin AAA by the wrist toward the school under flashlight illumination.
- AAA was reported missing the next day; barangay officials found her naked, decomposed body in a nearby bamboo grove.
- Autopsies revealed a cracked temporal skull with brain matter extrusion, a half-inch laceration below the left labia, multiple contusions, and vaginal tears consistent with forceful sexual assault.
Prosecution Evidence
- BBB (victim’s uncle) positively identified ZZZ as the last person seen with AAA before her disappearance.
- SPO3 Lavarias and other officers recovered the corpse, recorded BBB’s identification, interviewed ZZZ’s brother YYY, and requested an autopsy.
- Dr. Paz Q. Mejia’s initial autopsy noted skull fracture, labial laceration, and advanced decomposition but could not quantify the time of death or precise nature of genital injury.
- Dr. Ronald Bandonill confirmed advanced decomposition, facial and limb contusions, genital contusions, vaginal tears, and traumatic cerebral contusion as cause of death.
- CCC (victim’s father) testified to AAA’s age (11) and expenses of P20,000 for internment and P30,000 for miscellaneous costs; prayed for damages.
Defense Evidence and Alibi
- ZZZ claimed he was 15 at the time; said he watched television at his grandmother’s house with YYY and AAA, then went home without noticing AAA’s departure.
- He fled to Tarlac on May 22, 1996 under the alias “Peter Viray” when he learned of the charges.
- YYY initially told poli