CIRCUMSTANTIAL EVIDENCE IS ADMISSIBLE IN COMPOSITE CRIMES SUCH AS RAPE WITH HOMICIDE PEOPLE V. EDMUNDO VILLAFLORES y OLANO G.R. No.

184926, April 11, 2012 BERSAMIN, J: FACTS: The accused in this case is Edmundo Villaflores who was also known as Batman in their neighborhood and was known to be a drug-addict. The victim is a four-year old girl named Marita. On July 2, 1999, Marita was last seen by her mother Julia to be playing at the rear of their residence, when her mother noticed that she was missing, she called her husband who rushed home to find their daughter. At 6:00AM of July 3, 1999, they found Maritas lifeless body covered with blue and yellow sack five houses away from their home. The result of the postmortem examination showed that the child was raped and the cause of death is asphyxia by strangulation. Upon police investigation, two (2) witnesses who were Aldrin Bautista and Jovy Stadium pointed Villaflores as the culprit. Both witnesses narrated that at about 10:00AM on July 2, 1999, they saw Villaflores leading Maria by the hand. At noon, the three used shabu for a while, but the witnesses did not see Marita in the vicinity of Villaflores house. It was only on 3:00PM that they heard cries of a child. At about 7:00PM both witnesses saw Batman carrying a yellow sack which appears heavy, the same sack that he saw when they are still inside the house of Batman. The wife of the accused also gave a supporting testimony that on the night of July 2, 1999 she saw his husband place some sacks under their house and then went closer and saw a protruding elbow inside the sack, when she confronted his husband who was on drugs, Villaflores said it was nothing. Based from these circumstances, the RTC convicted Villaflores of a rape with homicide holding that the circumstantial evidence led to no other conclusion but that his guilt was shown beyond reasonable doubt. The Court of Appeals also affirmed the conviction. The accused appealed and argued that both RTC and CA erred in convicting him of a composite crime of Rape with homicide through circumstantial evidence. ISSUE: Can the accused be convicted of a composite crime of rape with homicide through circumstantial evidence? HELD: YES. In order to convict Villaflores for the composite crime of rape with homicide, the State must thus prove the concurrence of the following facts, namely: ( a) that Villaflores had carnal knowledge of Marita; (b) that he consummated the carnal knowledge without the consent of Marita; and ( c) that he killed Marita by reason of the rape. Under the RPC as amended, rape is always committed when the accused has carnal knowledge of a female under 12 years of age. The crime is commonly called statutory rape, because a female of that age is deemed incapable of giving consent to the carnal knowledge. Maritas Certificate of Live Birth disclosed that she was born on October 29, 1994, indicating her age to be only four years and eight months at the time of the commission of the crime on July 2, 1999. As such, carnal knowledge of her by Villaflores would constitute statutory rape. The crime becomes a composite crime of rape with homicide when it was made on the occasion of the rape, which refers to a killing that occurs immediately before or after, or during the commission itself of the attempted or consummated rape, for as long as the killing is lined to rape. Although the best evidence to prove rape is the testimony of the victim herself, the rule held that the Rules of Court allows circumstantial evidence to establish the commission of the crime as well as the identity of the culprit when the rape victim is herself killed; provided however, that such circumstantial evidence is sufficient for conviction.

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A circumstantial evidence is sufficient when (1) there is more than one circumstance, (2) the facts from which the inferences derived are proven and (3) the combination of all circumstances is such as to produce a conviction beyond reasonable doubt. With the circumstances provided by the testimonies of different witnesses, the RTC and the CA appreciated the circumstances together and were seen as strands which create a pattern and formed an unbroken chain that led to the reasonable conclusion that Villaflores, to the exclusion of all others, was guilty of rape with homicide.

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