GR 228828; (July, 2019) (Digest)
G.R. No. 228828 , July 24, 2019
People of the Philippines, Plaintiff-Appellee vs. ZZZ, Accused-Appellant
FACTS
The case involves the rape with homicide of an 11-year-old girl, AAA, on May 16, 1996. The prosecution’s case was built on circumstantial evidence. The victim’s uncle, BBB, testified that on the night of the incident, he saw the accused-appellant, ZZZ, dragging AAA by the wrist towards a school area. The following day, AAA was reported missing, and her decomposing, naked body was later discovered in a bamboo grove near the school. A medico-legal officer testified to findings of contusions on AAA’s genital area and a traumatic cerebral contusion as the cause of death, opining that she might have been sexually assaulted. The defense presented ZZZ, who claimed he was 15 years old at the time and denied the accusation, stating he was elsewhere watching television with a group that included AAA.
ISSUE
Whether the circumstantial evidence presented by the prosecution is sufficient to prove the guilt of the accused-appellant for the crime of rape with homicide beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court meticulously applied the rules governing circumstantial evidence, which requires that: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all the circumstances produces a conviction beyond reasonable doubt. The Court found these conditions satisfied by the confluence of proven facts: BBB’s eyewitness account of ZZZ dragging the victim toward the crime scene on the night she disappeared; the discovery of the victim’s body near that location; the medico-legal findings consistent with sexual assault and violent death; and ZZZ’s flight after the discovery of the body, which indicates guilt. The defense of alibi was rejected for being weak and unsubstantiated. However, the Court modified the penalty. Since it was established that ZZZ was 15 years old at the time of the commission of the crime, he was entitled to a privileged mitigating circumstance of minority under Article 68 of the Revised Penal Code. Applying the rules for a complex crime under Article 48, the penalty for rape with homicide is reclusion perpetua to death. With the mitigating circumstance of minority and no aggravating circumstances, the penalty imposed was reduced to reclusion perpetua.