PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LEONARDO FLORES, ALEX KING CRUZ, SERVILLANO PARIÑAS and ERNESTO SARSOZA, defendants-appellants.
FACTS
On the night of September 21, 1984, Mercedes Dulay was raped and killed in Barangay Inamotan, Manaoag, Pangasinan. Her body, bearing hack and stab wounds and with an ipil-ipil branch inserted into her vagina, was discovered the next morning. The police apprehended Leonardo Flores, who named his companions as Alex King Cruz, Servillano Pariñas, and Ernesto Sarsoza. The four were charged with rape with homicide and robbery. At arraignment, Cruz, Pariñas, and Sarsoza pleaded not guilty. Flores initially pleaded guilty, but the court entered a not guilty plea to ensure he had counsel. Upon rearraignment with counsel, Flores insisted on his guilty plea.
Flores subsequently testified for the prosecution, providing a detailed account. He stated that he, Cruz, Pariñas, and Sarsoza, after drinking and smoking marijuana, conspired to wait for the victim to rob, rape, and kill her. They ambushed Dulay, with Flores grabbing her. Cruz then proposed the rape, which all agreed to. They took turns raping her while the others held her down. After the rape, Sarsoza and Cruz stabbed her, and Cruz slashed her throat. They also robbed her of personal items. Flores’s testimony was corroborated by the victim’s mother regarding the stolen property and by medico-legal findings on the rape and violent death.
ISSUE
The primary issue is whether the guilt of the appellants for the complex crime of rape with homicide was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The trial court correctly found the appellants guilty of the special complex crime of rape with homicide under Article 335 of the Revised Penal Code, as amended. The legal logic rests on the credibility of Flores’s extrajudicial confession and its corroboration by evidence of corpus delicti. While an extrajudicial confession alone is insufficient for conviction, it becomes admissible against the confessant and his co-conspirators when corroborated by independent proof of the commission of the crime. Here, the medical findings-lacerations indicating rape, hack and stab wounds causing death, and the inserted branch-conclusively established the corpus delicti. This physical evidence corroborated Flores’s detailed confession, which vividly described the conspiracy, the sequential acts of rape, and the subsequent killing, thereby implicating all four appellants.
The Court rejected the defense of alibi and denial by the other appellants, noting they were weak and could not prevail over the positive identification and credible testimony. The aggravating circumstances of nighttime, abuse of superior strength, and evident premeditation were correctly appreciated. However, with the abolition of the death penalty under the 1987 Constitution, the penalty was reduced to reclusion perpetua for each appellant. The Court also modified the civil indemnity, awarding P50,000.00 to the victim’s heirs.
