GR 131478; (April, 2002) (Digest)
G.R. No. 131478; April 11, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAYMUNDO CORFIN, accused-appellant.
FACTS
On May 18, 1995, four-year-old Ad Jane Zabala went missing from her home in General Santos City. Her body was discovered the next day in a dry creek. An autopsy revealed she was in an advanced state of decomposition with a lacerated wound in the inguinal area and a lacerated, inflamed vagina. The cause of death was certified as hemorrhage secondary to rape. The prosecution presented circumstantial evidence to implicate accused-appellant Raymundo Corfin. Witnesses testified they saw Corfin talking with the victim near an abandoned store around 10:00-11:00 AM on the day she disappeared. Another witness claimed he later saw Corfin carrying the child. The victim’s panty was subsequently found in Corfin’s house during a warrantless search initiated by a barangay official, though Corfin was not present. The trial court convicted Corfin of Rape with Homicide and imposed the death penalty.
ISSUE
Whether the accused-appellant’s guilt for the crime of Rape with Homicide was proven beyond reasonable doubt based on the evidence presented.
RULING
The Supreme Court modified the conviction. The circumstantial evidence was insufficient to prove rape conclusively. The medical findings were equivocal; the examining physician testified the vaginal laceration could have been caused by an erect penis or any hard object, and the body’s advanced decomposition made precise determination difficult. The evidence did not establish the element of carnal knowledge with moral certainty. However, the chain of circumstances was adequate to establish homicide. The witnesses placed the accused-appellant with the victim just before her disappearance and death. His flight and failure to offer a credible alibi further indicated guilt. The warrantless seizure of the panty from his house was deemed illegal, rendering the item inadmissible, but the remaining evidence sufficed for a homicide conviction. The Court found him guilty of Homicide under Article 249 of the Revised Penal Code and imposed an indeterminate penalty of 12 years of prision mayor as minimum to 17 years and 4 months of reclusion temporal as maximum. He was ordered to pay civil indemnity, actual, and moral damages to the victim’s heirs.