G.R. No. 100912. July 6, 1995.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ZALDY CRISTOBAL y ALBARIN, accused-appellant.

FACTS

On the evening of September 22, 1989, in Mabato-bato, Mandaon, Masbate, Edna Cantubira was found dead in her home. The prosecution established that earlier that day, accused-appellant Zaldy Cristobal, who was drunk, told two different persons, Conrado Monterola and Pedra Cristobal, of his intent to kill Edna. Later that night, witness Ruben Escota testified that Cristobal, carrying a fan knife, invited him to go to Edna’s house because she was alone, but Escota refused. The central eyewitness, Teresa Cantubira, testified that around 11:00 p.m., she heard Edna’s cries for help. Proceeding to the house, she saw through an open door the accused, completely naked, lying on top of Edna and repeatedly stabbing her with a knife before slashing her neck.
An autopsy conducted by Dr. Luis Aguirre revealed the victim sustained 18 incised wounds and 20 stab wounds, including a severe neck wound severing the trachea and esophagus. The examination also noted fresh hymenal lacerations. The accused was charged with the complex crime of Rape with Homicide. The Regional Trial Court convicted him, sentencing him to reclusion perpetua and ordering him to indemnify the heirs. The accused appealed, challenging the credibility of the eyewitness and the sufficiency of evidence for rape.

ISSUE

Whether the trial court erred in convicting accused-appellant Zaldy Cristobal of the complex crime of Rape with Homicide beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The legal logic rests on the trial court’s superior position to assess witness credibility, a finding generally not disturbed on appeal absent clear error. The Court found no reason to overturn the trial court’s credence given to Teresa Cantubira’s eyewitness account, which was clear and detailed. Her testimony was corroborated by the testimonies of other prosecution witnesses who established the accused’s drunken state, his prior declarations of intent to kill the victim, and his possession of a knife and invitation to go to her house that night.
The accused’s defense of denial and alibi was deemed weak and unsubstantiated. The Court ruled that the killing was conclusively proven by Teresa’s testimony and the autopsy report. The element of rape was likewise established beyond reasonable doubt by the combined force of Teresa’s testimony that she saw the accused naked on top of the victim and the medical finding of fresh hymenal lacerations. The Court held it was highly improbable for the accused to undress merely to commit homicide, thereby logically inferring the rape. Consequently, all elements of the complex crime of Rape with Homicide were proven. The Court modified the civil indemnity, increasing it from P30,000 to P50,000 in accordance with prevailing jurisprudence.