G.R. No. 211027 , June 29, 2015.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JOSE BRONIOLA @ “ASOT”, Accused-Appellant.

FACTS

On February 28, 2000, AAA, a 13-year-old Grade VI pupil, left her house for school and did not return. Her lifeless body was found the next day in a grassy lot near an uninhabited farm hut at Sitio Kabanatian, Barangay Tumanding, Arakan, Cotabato. She had multiple hack wounds, and a post-mortem examination revealed hymenal lacerations and a whitish vaginal discharge. The cause of death was cardio-respiratory arrest secondary to hemorrhage from the multiple hacked wounds. An Information was filed charging Jose Broniola with rape with homicide. The prosecution presented circumstantial evidence, primarily the testimony of Alfredo Abag, who on February 28, 2000, at around 5:30 p.m., met the appellant on a shortcut road near where the body was found. Appellant had scratches on his face, was holding a blood-stained lagaraw (bolo), and appeared restless and uneasy. The prosecution also established a motive: the victim’s father (BBB) was the father-in-law of Lito Miguel, who had killed appellant’s father. The defense consisted of denial and alibi, with appellant claiming he was at home all day and did not know the victim or her father.

ISSUE

Whether the circumstantial evidence presented by the prosecution is sufficient to prove beyond reasonable doubt that appellant is guilty of the special complex crime of rape with homicide.

RULING

Yes. The Supreme Court affirmed the conviction. The crime of rape with homicide, where no eyewitnesses exist, may be proven by circumstantial evidence. The prosecution established an unbroken chain of circumstances leading to the reasonable conclusion that appellant was the perpetrator: (1) Appellant was met near the crime scene at the approximate time the victim went missing; (2) He had scratches, carried a blood-stained bolo, and was restless; (3) The victim’s body, found the next day, bore hack wounds consistent with a bolo attack and showed signs of rape; (4) The medical findings confirmed rape and homicide; (5) Appellant had a motive stemming from a prior killing involving their families; and (6) Appellant was evasive regarding his knowledge of this family conflict. These circumstances, taken together, meet the requirements of Section 4, Rule 133 of the Revised Rules on Evidence for circumstantial evidence to sustain a conviction. The defenses of denial and alibi, which were not substantiated by clear proof of the physical impossibility of appellant’s presence at the crime scene, are weak and cannot prevail over the positive circumstantial evidence. The Court affirmed the penalty of reclusion perpetua without parole and the awards of civil indemnity (₱100,000), moral damages (₱75,000), and exemplary damages (₱30,000), all with 6% interest from finality until fully paid.