GR 233199; (November, 2018) (Digest)
G.R. No. 233199, November 05, 2018
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ARIEL MANABAT CADENAS AND GAUDIOSO MARTIJE, ACCUSED-APPELLANTS.
FACTS
Accused-appellants Ariel Cadenas and Gaudioso Martije were charged with Rape with Homicide for the death of AAA on February 12, 2012. The prosecution presented circumstantial evidence, primarily the testimony of Dindo Escribano, who claimed he saw both appellants running from the victim’s house on the night of the crime. The victim was found naked with her pants pulled down, bearing wounds. A barangay tanod testified that Cadenas voluntarily admitted to the killing upon arrest. The medical examiner confirmed death was due to skull fracture from a blunt object and noted wounds on the mons pubis and nipple, though no spermatozoa was found. The defense consisted of alibis, with both appellants claiming they were elsewhere during the incident and denying any involvement.
The Regional Trial Court convicted both appellants of Rape with Homicide, sentencing them to reclusion perpetua without parole. The Court of Appeals affirmed this conviction. The appellants then elevated the case to the Supreme Court, arguing that the evidence was insufficient to prove their guilt beyond reasonable doubt.
ISSUE
Whether the guilt of accused-appellants for the special complex crime of Rape with Homicide was proven beyond reasonable doubt.
RULING
No. The Supreme Court reversed the lower courts’ decisions and acquitted both accused-appellants. The Court meticulously examined the evidence and found it insufficient to establish guilt beyond the required moral certainty. The prosecution’s case relied heavily on circumstantial evidence, which must constitute an unbroken chain leading to one fair and reasonable conclusion pointing to the accused, to the exclusion of all others, as the guilty person. Here, the chain was broken and failed this test.
The Court found the testimony of eyewitness Escribano unreliable and inconsistent. His claim of seeing the appellants flee was uncorroborated and contradicted by his own prior statements and the testimony of the victim’s partner. The alleged extrajudicial confession by Cadenas to the barangay tanod was inadmissible as it was made without the presence of counsel, violating constitutional rights. Critically, the medical findings did not conclusively prove rape. The wounds on the mons pubis and nipple, while suggestive, were not definitive evidence of sexual assault, and the absence of spermatozoa or clear signs of penetration created reasonable doubt. The prosecution failed to prove the element of carnal knowledge, a requisite for the complex crime of Rape with Homicide. Consequently, the evidence did not overcome the constitutional presumption of innocence. The appeal was granted, and both appellants were ordered immediately released.