G.R. No. 130612 May 11, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BERNARDINO DOMANTAY, @ “JUNIOR OTOT,” accused-appellant.

FACTS

On October 17, 1996, the body of six-year-old Jennifer Domantay was discovered in a bamboo grove in Guilig, Malasiqui, Pangasinan, bearing 38 stab wounds. The initial medical examination noted her vaginal canal admitted a little finger with minimal resistance, prompting a recommendation for an NBI autopsy. The police investigation focused on accused-appellant Bernardino Domantay, a relative of the victim. He was apprehended and allegedly confessed to the killing, leading to the recovery of a bayonet he had given to relatives. The NBI autopsy later revealed a complete hymenal laceration, leading to the filing of an information for rape with homicide.
At trial, the prosecution presented witnesses. Edward Domantay testified that on the morning of the incident, the intoxicated accused-appellant, while carrying a bayonet, declared he would “massacre somebody.” Child witness Jiezl Domantay saw the accused-appellant walking ahead of the victim toward the bamboo grove where she was later found. Lorenzo Domantay saw the accused-appellant acting nervously at that same location. Tricycle driver Joselito Mejia stated the accused-appellant, appearing afraid, sought a ride out of town shortly after. The medico-legal expert confirmed the hymenal laceration consistent with sexual assault.

ISSUE

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

RULING

Yes. The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua and the awarded damages. The Court found the circumstantial evidence sufficient to establish moral certainty of the accused-appellant’s guilt. The combination of events—his drunken declaration of intent to harm, being seen leading the victim to the crime scene, his nervous presence at the location, his attempt to flee, his extrajudicial confession leading to the murder weapon, and the medical finding of rape—forms an unbroken chain leading to the reasonable conclusion that he committed the crime. The Court ruled that circumstantial evidence is sufficient for conviction if: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all the circumstances produces a conviction beyond reasonable doubt. All these requisites were met. The Court also upheld the credibility of the child eyewitness, noting her testimony was straightforward and consistent. The defense of alibi was rightly rejected for being weak and unsubstantiated. The death penalty was reduced to reclusion perpetua in accordance with prevailing jurisprudence, as the information did not allege the victim’s minority as a qualifying circumstance.