GR 63609; (June, 1989) (Digest)
G.R. No. 63609 , June 6, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANICIO MASONGSONG, accused-appellant.
FACTS
Accused-appellant Anicio Masongsong was charged with Rape with Homicide. The information alleged that on August 16, 1982, in Laguna, he, armed with a deadly weapon, by means of force and intimidation, succeeded in having carnal knowledge of 67-year-old Amanda Reyes Vda. de Matibag against her will. On the occasion thereof, after the sexual abuse, he tied her hands, feet, and mouth, and threw her into an irrigation canal, causing her death by drowning. Upon arraignment, he pleaded not guilty despite having executed an extra-judicial confession. After trial, the Regional Trial Court found him guilty beyond reasonable doubt and sentenced him to death.
The prosecution evidence established that the appellant, along with his uncle Sergio Ocampo, went to the victim’s house to steal. Appellant ascended the house, raped the victim at knifepoint, and thereafter tied her up. When she later freed herself and attempted to flee, he recaptured her, bound her securely, and threw her into an irrigation canal where she drowned. The victim’s body was discovered the next day, still bound, with a post-mortem examination confirming vaginal laceration and death by massive water swallowing. The stolen pig and a pair of shoes linked the appellant and his uncle to the crime scene.
ISSUE
Whether the accused-appellant is guilty beyond reasonable doubt of the crime of Rape with Homicide.
RULING
Yes, the Supreme Court affirmed the conviction but modified the penalty and indemnity. The Court found the extra-judicial confession admissible and credible, as it was corroborated on material points by independent evidence, including the physical findings on the victim’s body, the recovery of stolen property, and the appellant’s own conduct. The Court rejected the defense of alibi, noting it was not only physically possible for the appellant to be at the crime scene but his presence was positively established. His flight to Siniloan immediately after the incident and his silence when confronted were deemed indicative of guilt.
The legal logic centered on the sufficiency of circumstantial evidence to establish guilt beyond reasonable doubt, especially in the absence of direct eyewitnesses to the rape itselfβa circumstance the Court noted is not unusual for such a crime. The confluence of the corroborated confession, the physical evidence, and the appellant’s flight collectively formed an unbroken chain leading to the inescapable conclusion of his culpability. However, pursuant to the constitutional prohibition, the death penalty was reduced to reclusion perpetua, and the civil indemnity was increased to Thirty Thousand Pesos (P30,000.00).
