GR 130590; (October, 2000) (Digest)
G.R. No. 130590; October 18, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RANILLO PONCE HERMOSO alias “ALLAN,” accused-appellant.
FACTS
On the evening of June 2, 1996, seven-year-old Glery P. Geoca failed to return home from school in Barangay Little Baguio, Imelda, Zamboanga del Sur. Her father, Ireneo Geoca, organized a search party with Barangay Captain Sonny Boy Altamera. Witnesses, including Josephine Gonzales and store owner Lilia Bartido, reported seeing the victim in the company of accused-appellant Ranillo Ponce Hermoso earlier that afternoon. The search team located Hermoso, who initially denied any knowledge of the girl’s whereabouts. Later that night, Naciansino Hermoso found and presented a wallet containing the accused-appellant’s identification cards. Confronted with this evidence, Hermoso confessed to raping and killing the child and led authorities to the victim’s body.
ISSUE
Whether the guilt of accused-appellant for the crime of rape with homicide was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the chain of circumstantial evidence sufficient to establish guilt beyond reasonable doubt. The prosecution proved that the accused-appellant was the last person seen with the victim, his personal wallet was found near the crime scene, and his subsequent extrajudicial confession—made after being confronted with this physical evidence—led directly to the discovery of the victim’s body, which showed clear signs of rape and violent death. The Court emphasized that while the confession alone was inadmissible due to the absence of counsel, it became admissible as part of the res gestae because it was made spontaneously after the discovery of the wallet and, crucially, it led to the discovery of the victim’s body, an fact unknown to the authorities and confirms the confession’s veracity. This falls under the “discovery of fact” exception to the rule on inadmissibility of uncounselled confessions. The medical findings of rape and homicide, corroborated by the circumstantial evidence, left no reasonable doubt of his culpability. The penalty of death was affirmed, but the awarded damages were modified to conform with prevailing jurisprudence.