G.R. No. 111285 January 24, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VICENTE VALLA, accused-appellant.

FACTS

On April 14, 1991, eight-year-old Dyesebel de la Cruz was reported missing in Barangay Ilayang Tayuman, San Francisco, Quezon. Earlier that day, a witness heard what she recognized as Dyesebel’s voice, sounding as if she was being strangled, from a forested area. A search party was organized, led by Barangay Captain Aristeo Allarey. The victim’s father informed the captain that Dyesebel had last been seen with her cousin, the accused-appellant Vicente Valla, to watch a ricefield. Appellant was found drinking elsewhere and initially failed to report when summoned.
The following day, appellant joined the search party. The child’s body was discovered near a riverbank, bearing injuries including a depressed skull, cigarette burns on her pubic area, and hymenal lacerations indicating rape. Upon discovery, appellant was immediately confronted by the group. In the presence of the barangay captain, the victim’s father, and other witnesses, appellant admitted to raping and killing Dyesebel. He expressed remorse, even offering his own daughter to the victim’s father as compensation. Appellant was subsequently arrested.

ISSUE

Whether the guilt of accused-appellant Vicente Valla for the crime of rape with homicide was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the appellant’s extrajudicial confession, made spontaneously before barangay authorities and the victim’s father, to be credible and admissible as evidence of guilt. The legal logic rests on the doctrine that an extrajudicial confession, when made voluntarily and corroborated by other evidence, constitutes strong proof of guilt. Here, the confession was corroborated by the physical findings of the medico-legal officer, which confirmed rape and violent death, and by the appellant’s own conduct, such as avoiding initial summons and his peculiar offer of his daughter. The Court rejected the appellant’s denial and alibi, which were inherently weak defenses, especially when weighed against the positive and credible testimony of prosecution witnesses regarding his confession. The crime was properly classified as rape with homicide under Article 335 of the Revised Penal Code. The penalty of reclusion perpetua was correctly imposed, as the death penalty was suspended under the 1987 Constitution . The Court modified the damages, increasing civil indemnity to P100,000.00, awarding moral damages of P50,000.00, and exemplary damages of P20,000.00 due to the aggravating circumstance of ignominy from the cigarette burns.