G.R. No. 138936 . January 30, 2001.
PEOPLE OF THE PHILIPPINES, appellee, vs. ROLANDO SOLIS y SEGOVIA, appellant.

FACTS

The appellant, Rolando Solis y Segovia, was charged with the special complex crime of rape with homicide of Lilibeth Balbuena, an 8-year-old retarded child. On September 20, 1990, the victim’s parents, Sabiniano and Lucia Balbuena, arrived home and saw appellant cutting banana leaves about ten meters away. They later discovered Lilibeth missing. Sabiniano searched for her and encountered appellant multiple times, who each time claimed to have seen a child crossing a bridge. Sabiniano eventually saw appellant running away with wet pants and carrying banana leaves. A neighbor, Zelbred Santillan, also saw appellant wet and in a hurry. Another neighbor, Rolando Oliveros, later found Lilibeth’s body covered with banana leaves in a ditch about 100 meters from her house. The police and medico-legal officer, Dr. Romeo Gellada, responded. The autopsy revealed a fatal stab wound on the chest and genital findings indicating rape (swollen and congested labia, lacerated hymen, and cervical smear positive for spermatozoa). The police went to appellant’s house; his parents surrendered a knife with a sticky substance akin to blood. Appellant eluded arrest for about four years before being apprehended. The Regional Trial Court of Bacolod City found him guilty beyond reasonable doubt and sentenced him to reclusion perpetua, along with damages.

ISSUE

Whether the circumstantial evidence presented by the prosecution is sufficient to prove the guilt of the appellant for the crime of rape with homicide beyond reasonable doubt.

RULING

No. The Supreme Court reversed the decision of the Regional Trial Court and acquitted the appellant. The Court held that the circumstantial evidence was insufficient to support a conviction. The established circumstances were: (1) appellant was seen cutting banana leaves near the victim’s house on the morning of the crime; (2) he gave misleading information to the victim’s father during the search; (3) he was seen running away with wet pants and carrying banana leaves; (4) the victim’s body was found covered with banana leaves; (5) a knife with a sticky substance was surrendered by his parents; and (6) he evaded arrest for four years. The Court ruled that these facts did not constitute an unbroken chain leading to the fair and reasonable conclusion that appellant was the perpetrator. The evidence failed to show that appellant was at the precise location of the crime at the time it was committed, that he had any interaction with the victim, or that the knife surrendered was conclusively the murder weapon. His flight was deemed an unreliable indicator of guilt. The prosecution did not satisfy the requirements for circumstantial evidence under the Rules of Court, as the facts proven were consistent with innocence. The inference of guilt was improperly drawn from other inferences. Accordingly, appellant was acquitted on reasonable doubt and ordered released immediately unless detained for another lawful cause. The award of damages was deleted.