G.R. No. L-28255 November 25, 1983
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARTIN MAGTIRA y DELA CRUZ, accused-appellant.

FACTS

The case involves the rape and homicide of ten-year-old Clarita Constantino. On the afternoon of June 9, 1967, in Masinloc, Zambales, the victim was playing with her siblings near the house of the accused-appellant, Martin Magtira. Magtira beckoned Clarita to come upstairs to his house, and she obeyed. He then gestured for her siblings to leave. When Clarita failed to return home, her mother searched for her and was informed by her son that Magtira had called Clarita. The mother and a neighbor went to Magtira’s house, where they discovered Clarita’s lifeless body on the floor, covered by a mat. Her dress was bloodstained, her panty was missing, and a portion of a man’s sweatshirt was inserted into her vagina.
A postmortem examination revealed a lacerated hymen, vaginal lacerations and hemorrhage, and contusions on her neck and thighs. The cause of death was strangulation aggravated by hemorrhage. Magtira was arrested and initially denied involvement, but later executed a sworn statement (Exhibits “C” and “C-1”) before the Municipal Judge, admitting to the crime while claiming intoxication. He was convicted of rape with homicide and sentenced to death by the trial court.

ISSUE

The primary issues on automatic review were: (1) the admissibility of the accused’s extrajudicial confession, and (2) the sufficiency of the circumstantial evidence to prove guilt beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua, as the death penalty was unconstitutional at the time of the decision. The Court held the extrajudicial confession was admissible. It was given voluntarily, with Magtira duly informed of his rights to remain silent and to counsel in a language he understood. The confession was made before a municipal judge in the presence of witnesses, and the accused affirmed its contents under oath. His claim of intoxication was belied by his coherent and detailed responses during the questioning.
Furthermore, the Court ruled that the totality of the circumstantial evidence constituted an unbroken chain leading to the inescapable conclusion of Magtira’s guilt. The evidence established that Magtira was the last person seen with the victim when he summoned her into his house. The victim’s body was discovered in his home shortly after. The medical findings conclusively proved rape and homicide. His initial false denial and flight were indicative of guilt. His confession, corroborated by the physical evidence and circumstances, completed the proof. The confluence of the admissible confession and the corroborating circumstantial evidence satisfied the requirement of proof beyond reasonable doubt.