GR 119352; (June, 1999) (Digest)
G.R. No. 119352 June 8, 1999
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CELESTINO D. PAYOT, accused-appellant.
FACTS
The accused-appellant, Celestino D. Payot, was charged with the special complex crime of rape with homicide. The information alleged that on January 29, 1991, in Bansalan, Davao del Sur, Payot, conspiring with two others, raped a 12-year-old girl, Jocelyn Bosbos, and killed her on the occasion thereof. The trial court convicted Payot but acquitted his two co-accused on grounds of reasonable doubt. The prosecution’s case was built on circumstantial evidence. Key witnesses testified that Payot was seen arriving at a neighbor’s house on the night of the crime, agitated, muddy, and with blood on his knee and forearm. The victim’s body was found near a canal with injuries consistent with rape and violent assault. Forensic analysis showed human blood of type AB on Payot’s clothing, while the victim’s blood type was AB and Payot’s was A.
ISSUE
The core issue is whether the circumstantial evidence presented by the prosecution is sufficient to prove beyond reasonable doubt that Payot committed the crime of rape with homicide.
RULING
Yes, the conviction is affirmed. The Supreme Court upheld the trial court’s finding that the totality of the circumstantial evidence meets the required standard for conviction. The legal logic rests on the principle that conviction can be based on circumstantial evidence provided the circumstances constitute an unbroken chain leading to a fair and reasonable conclusion of the accused’s guilt. The Court found the following circumstances duly proven and consistent with each other: Payot’s presence near the crime scene; his agitated state and physical condition with bloodstains shortly after the crime; the forensic evidence linking the blood on his clothes to the victim’s blood type; his flight and resistance upon arrest; and his failure to provide a credible explanation for the incriminating evidence. These facts, taken together, form a complete chain that excludes any reasonable hypothesis of innocence. The Court modified the civil liabilities, increasing the indemnity for rape with homicide to P100,000.00 and awarding moral damages of P50,000.00 to the victim’s heirs, in accordance with prevailing jurisprudence.