GR 131618 1999 (Digest)
G.R. No. 131618 . July 6, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOMINADOR MANGAT Y PALOMATA, accused-appellant.
FACTS
On July 10, 1995, thirteen-year-old Kristal Manasan left her home in Barangay Lusong, San Agustin, Romblon, and failed to return. Her decomposing body was discovered three days later in a rock hole along Lusong River; she was nude and her clothing was found nearby. Dr. Cynthia Baradon-Mayor conducted an autopsy and certified the cause of death as multiple hemorrhage due to skull fracture. The examination further revealed multiple hymenal and anal lacerations, with her bladder and intestines prolapsed, leading to the conclusion that she was brutally raped and murdered.
The prosecution’s case hinged on the eyewitness account of Pacifico Magramo, a farmer. He testified that on July 10, at around 2:30 p.m., he saw the accused, Dominador Mangat, pushing the naked, lifeless body of Kristal into a rock hole. Mangat threatened him not to divulge what he saw. Corroborative testimony from Jaime Magramo placed the accused at the crime scene earlier that day. After the body was found, the accused and his father offered to settle the case amicably with the victim’s family, which was documented in an affidavit by SPO1 Fajutag.
ISSUE
The core issue is whether the guilt of the accused for the complex crime of rape with homicide was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The trial court’s assessment of witness credibility is accorded great respect, and the Court found no reason to deviate from its findings. Pacifico Magramo’s positive identification of the accused was clear, credible, and consistent. His initial fear to report did not undermine his testimony; it was a natural reaction to the direct threat from the accused. His eventual disclosure was credible and corroborated by the physical evidence and the accused’s own conduct.
The accused’s defense of denial and alibi was inherently weak and could not prevail over the positive identification. His claim of being elsewhere was not physically impossible to achieve from the crime scene. Furthermore, the accused’s conduct, specifically the offer for an amicable settlement, constituted an implied admission of guilt. Such an offer is admissible as evidence against the offeror under the rules of evidence. The medical findings of rape and violent homicide, combined with the eyewitness testimony and the accused’s own actions, formed an unbroken chain of evidence leading to the inescapable conclusion of his guilt. The complex crime of rape with homicide was thus established beyond reasonable doubt. The penalty of death was affirmed, with modifications to the civil indemnity and moral damages awarded.
