GR L 35705; (August, 1982) (Digest)
G.R. No. L-35705 August 21, 1982
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RICARDO UMALI y MARASIGAN, accused-appellant.
FACTS
The case involves the automatic review of the death penalty imposed on Ricardo Umali for the crime of rape with homicide. The victim was Corazon Panghulan, a 13-year-old student. On September 17, 1970, in Canlubang, Calamba, Laguna, the accused was seen by eyewitnesses, Teodora Gaynilo and her husband, forcibly dragging the victim into a sugarcane field. The witnesses reported the abduction to the authorities. The search for Corazon ended with the discovery of her body, bearing signs of sexual assault and strangulation.
The prosecution presented a detailed account, including the accused’s extrajudicial confession where he admitted to raping the minor twice and subsequently strangling her to death. The defense, however, interposed an alibi, claiming the accused was elsewhere at the time of the crime. The trial court rejected the alibi, giving full credence to the prosecution’s evidence, and convicted Umali.
ISSUE
Whether the guilt of the accused for the crime of rape with homicide was proven beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction. The Court meticulously reviewed the evidence and found the prosecution’s version credible and consistent. The eyewitness testimony of Teodora Gaynilo, who positively identified the accused dragging the victim, was deemed reliable and unshaken. The Court upheld the trial court’s assessment of witness credibility, noting the time-honored principle that factual findings of the trial court are accorded great respect. The accused’s extrajudicial confession, while corroborative, was not the sole basis for conviction; the eyewitness account and circumstantial evidence sufficiently established his guilt. The defense of alibi was correctly dismissed for being weak and unsubstantiated, especially in light of the positive identification. The crime of rape with homicide, a capital offense, was thus proven beyond reasonable doubt. However, the Court modified the decision to include civil indemnity, ordering the accused to pay the heirs of Corazon Panghulan the sum of P12,000.00. The penalty of death was affirmed.