G.R. No. 137280 . March 13, 2002.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PABLO TABLON Y CENIZA, accused-appellant.

FACTS

On August 16, 1996, the decomposing body of Angelina Abapo was discovered near the Ormoc District Hospital. An autopsy revealed a stab wound and that her pants and panties were at her ankles, with her thighs drawn apart. She was last seen alive on August 6, 1996. Investigation led to Pablo Tablon, who, upon arrest, executed a sworn statement admitting that he stabbed the victim to overcome her resistance when he tried to rape her, and she died after the sexual assault. He confessed to hiding the body.
During trial, Tablon recanted his extrajudicial confession, claiming it was coerced through manhandling. He presented a new narrative of self-defense. He testified that he and the victim had a prior romantic encounter. On the night in question, after drinking with others, he retired to a nearby house. He claimed an unidentified intruder attacked him in the dark; he wrestled away a knife and stabbed the assailant, only to later discover it was Angelina Abapo. He panicked, hid the body, and fled.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Tablon is guilty of the special complex crime of rape with homicide.

RULING

The Supreme Court affirmed the conviction and imposed the death penalty. The Court found the extrajudicial confession, detailing the rape and killing, to be credible and voluntarily given. It was executed with the assistance of counsel from the Public Attorney’s Office, and Tablon failed to substantiate his claim of coercion with clear evidence. This detailed confession was corroborated by physical evidence: the victim’s lowered clothing and exposed genitalia were consistent with a sexual assault, and the solitary stab wound indicated a killing. Tablon’s alternative story of self-defense was inherently unbelievable. The claim of an unprovoked nighttime attack by the victim, whom he allegedly did not recognize until after stabbing her, defies logic and was unsupported by any evidence. His subsequent acts of concealing the body and fleeing were indicative of guilt, not innocence. The combination of his credible confession and the corroborative physical evidence established his guilt beyond reasonable doubt for the crime of rape with homicide under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659 . The penalty was properly imposed at death. The Court modified the civil indemnity to P100,000.00 and maintained the award of moral damages.