People vs. Villaflores

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 Marita’s 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...