G.R. No. 253467 . June 27, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. PEDRO RAMA, JR. Y YBAÑEZ A.K.A. “KABAYO,” ACCUSED-APPELLANT.

FACTS

The accused-appellant, Pedro Rama, Jr., was charged with the special complex crime of rape with homicide of an 11-year-old minor, AAA. The incident occurred on the morning of February 12, 2013, in a sugarcane field. AAA left her house to defecate in the field and did not return. Her mother, BBB, found her unconscious in the field. While being taken to the hospital, AAA regained consciousness and described her aggressor as a neighbor with long hair, wearing a red and blue shirt, and stated she scratched the right portion of his body. AAA died two hours later.
Prosecution witness CCC, AAA’s brother, testified that while searching for his sister, he saw the long-haired appellant walking away from the field, shirtless, with mud, scratches, and blood on his right abdomen. Prosecution witness Jimenez testified that he saw appellant, wearing a red and blue shirt, heading towards the sugarcane field around 5:00 AM and returning around 6:30 AM, shirtless, with a soiled body and scratches on his abdomen. Jimenez also stated appellant looked shocked and nervous during the commotion. PO3 Lopez recovered a red and blue shirt from the crime scene, which Jimenez identified as belonging to appellant. PO3 Lopez arrested appellant and noted scratches on his abdomen.
Dr. Tan, the attending physician, conducted a post-mortem examination and determined the cause of death was “asphyxia – cardiac arrest secondary to intrathoracic injuries secondary to rape.” He found a fresh hymenal laceration and injuries consistent with strangulation. Dr. Tan also examined appellant and found linear abrasions on his abdomen and other areas, which he opined appeared to be fingernail scratches, possibly from a defensive action.
The defense presented an alibi, with appellant claiming he was at home repairing his house from 5:00 AM to 9:00 AM on the day of the incident, supported by testimonies from his daughter and a friend. Appellant denied knowing AAA, owning the recovered shirt, or having scratches on his body.
The Regional Trial Court convicted appellant of rape with homicide based on circumstantial evidence and sentenced him to reclusion perpetua without parole, plus damages. The Court of Appeals affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for the special complex crime of rape with homicide based on circumstantial evidence.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that the conviction was sufficiently supported by an unbroken chain of circumstantial evidence that led to the inescapable conclusion that appellant was the perpetrator. The circumstances established were: (1) AAA’s ante-mortem statement describing her attacker, which matched appellant’s appearance; (2) appellant was seen going to and coming from the crime scene at the relevant time; (3) appellant was seen shirtless with mud and scratches after the incident; (4) the recovered shirt from the scene was identified as his; (5) the medical findings confirmed AAA was raped and strangled; and (6) the defensive wounds found on appellant were consistent with AAA’s statement that she scratched her attacker. The defense of alibi was weak and could not prevail over the positive circumstantial evidence. The penalty of reclusion perpetua without parole and the awarded damages were affirmed.