G.R. No. 125808 , September 3, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENE TAPALES y SUMULONG, accused-appellant.

FACTS

On January 20, 1995, the lifeless body of Mildred Calip, a second-year Medical Technology student, was found on Lira Street, Lores Country Homes, Antipolo, Rizal. An autopsy revealed she sustained 25 punctured wounds, 3 stab wounds, 6 contusions, 2 linear abrasions, and fresh hymenal lacerations, with the cause of death being hemorrhage from multiple punctured wounds on her neck. Rene Tapales y Sumulong, along with two John Does, was charged with the complex crime of rape with homicide. The venue of the trial was transferred from Antipolo to the Regional Trial Court of Manila. The prosecution presented several witnesses. Ferdinand Calip, Mildred’s brother, testified that at around 5:30 a.m. on January 20, he accompanied Mildred to a tricycle, where he saw Tapales already on board. Randy Ejara, a tricycle driver, testified that at around 5:45 a.m., he saw three tricycles, one with a white sidecar and black mudguard, and identified Tapales as a passenger who appeared afraid and agitated; the tricycle then sped away. Fiscal Edilberto H. Calip, Mildred’s father, testified about finding the body. Barangay tanods Rogelio Adan and Nelson Baran testified that at 3:00-3:30 a.m. on January 21, they saw Tapales near the crime scene carrying a candle; when questioned, Tapales allegedly stated he was there to light a candle so Mildred’s parents would forgive him, and that he knew Mildred and her killers. They arrested him and brought him to the police, where he was found to have abrasions, hematomas, contusions, and scratches, and was allegedly wearing inverted, blood-stained briefs. Tapales denied involvement, presenting an alibi that he was at home asleep at the time of the crime, and claimed he went to the crime scene only to pray for Mildred’s soul. He denied making the statements attributed to him by the tanods and denied the condition of his clothing at the police station. The trial court convicted Tapales of rape with homicide based on circumstantial evidence and imposed the death penalty.

ISSUE

Whether the circumstantial evidence presented by the prosecution is sufficient to prove beyond reasonable doubt that accused-appellant Rene Tapales y Sumulong is guilty of the complex crime of rape with homicide.

RULING

The Supreme Court ACQUITTED accused-appellant Rene Tapales y Sumulong. The Court found that the circumstantial evidence presented did not meet the required standard of proof beyond reasonable doubt. The circumstances cited by the trial court did not constitute an unbroken chain leading to the conclusion that Tapales was the perpetrator. Specifically: (1) The testimony of Ferdinand Calip that Tapales was a co-passenger in the tricycle was not conclusive of guilt. (2) The testimony of Randy Ejara was deemed unreliable as he could not have positively identified Tapales from a distance of three meters in the early morning light while the tricycle was moving, and his description of Tapales’s demeanor was speculative. (3) Tapales’s presence at the crime scene the following morning to light a candle, while suspicious, did not directly prove he committed the crime; his explanation, though unusual, was not inherently impossible. (4) The physical injuries found on Tapales were not conclusively linked to the crime, as there was no evidence (like skin, blood, or tissue under the victim’s fingernails) directly connecting them to a struggle with the victim. (5) The claim about the inverted and blood-stained briefs was not substantiated by clear evidence. The Court emphasized that circumstantial evidence must be acted upon with extreme caution, especially in capital cases, and all circumstances must be consistent with each other, consistent with the hypothesis that the accused is guilty, and inconsistent with any other rational hypothesis except that of guilt. These requisites were not satisfied. The defense of alibi, while weak, gained significance in light of the prosecution’s failure to establish guilt beyond reasonable doubt. The decision of the trial court was REVERSED and SET ASIDE.