G.R. No. 135562 November 22, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENITO BRAVO, accused-appellant.

FACTS

On January 15, 1994, the decomposing body of nine-year-old Juanita “Len-len” Antolin was discovered in a vacant lot in Santiago City. An autopsy revealed a skull fracture and vaginal lacerations, with the cause of death determined as cerebral hemorrhage. An Information for rape with homicide was filed against Benito Bravo. The prosecution’s case hinged on the testimony of Evelyn San Mateo, the victim’s eight-year-old cousin, who stated that on the evening of January 12, 1994, she saw the appellant approach them as they watched television from a neighbor’s window. Bravo invited Len-len to a birthday party, promising Coke and balut, and Len-len left with him. The neighbor, Gracia Monahan, corroborated seeing Bravo talk to the girls. Police Chief Alexander Mico testified that Bravo, when informally questioned, admitted being with the girl and carrying her while drunk but claimed not to remember his actions.
The defense presented a different narrative. Bravo testified that on the evening of January 12, he was drinking with friends until 7:30 PM, went straight home to care for his sick mother, and did not see the girls. He denied the crime, stating the victim was his godchild, and claimed his admission was coerced after a warrantless arrest. His brother and employer corroborated his alibi and good moral character. The trial court convicted Bravo of rape with homicide and sentenced him to death, prompting this automatic review.

ISSUE

Whether the guilt of the accused-appellant, Benito Bravo, for the crime of rape with homicide has been proven beyond reasonable doubt.

RULING

The Supreme Court ACQUITTED the accused-appellant. The Court emphasized that conviction must rest on proof beyond reasonable doubt, which requires an unbroken chain of facts leading to the conclusion that the accused is guilty to the exclusion of all others. Here, the prosecution evidence was insufficient. The sole circumstantial evidence was that Bravo was seen with the victim on January 12, but her body was found on January 15. The approximate time of death was never established, as the autopsy report, while admitted, did not specify it, and the testifying physician was discharged. This two-day gap presented a wide range of possibilities as to the perpetrator. The Court ruled that the single circumstance of being last seen with the victim, without more, is grossly inadequate to overcome the constitutional presumption of innocence. The alleged extrajudicial admission was also inadmissible, as it was obtained without informing Bravo of his constitutional rights during custodial investigation. While the crime was heinous, the Court held that the trial court may have been swayed by human indignation. When evidence falls short of the required quantum, the presumption of innocence must prevail. The judgment was reversed, and Bravo was ordered released.