People vs. Villaflores (Case Digest)

People vs. Villaflores (Case Digest)

G.R. No.  184926, April 11, 2012

By: G-one T. Paisones

Topic: Meaning of Special Complex Crime

Subject: Legal Research

FACTS:

Marita had been playing at the rear of their residence in Bagong Silang, Caloocan City; Julia, her mother, first noticed her missing from home on July 2, 1999.  Manito (father of Marita) rushed home and arrived there at about 2 pm, and immediately he and Julia went in search of their daughter. They did not find her. On the next day, Manito reported to the police that Marita was missing.  In her desperation, Julia sought out a clairvoyant (manghuhula) in an adjacent barangay, and the latter hinted that Marita might be found only five houses away from their own. Following the clairvoyants direction, they found Maritas lifeless body inside the comfort room of an abandoned house about five structures away from their own house. Julia had been tortured and strangled till death.

Two witnesses, Aldrin Bautista and Jovy Solidum, who indicated that Villaflores might be the culprit who had raped and killed Marita. The police thus arrested Villaflores on July 3, 1999 just as he was alighting from a vehicle. They saw Edmundo Villaflores, known in the neighborhood by his Batman tag and a neighbor of the [victims family], leading Marita by the hand (umakay sa bata). 

            No direct evidences are presented by the prosecution; only circumstantial evidence of the statement of two witnesses outline above.

Issues

Whether or not CA gravely erred in finding him guilty beyond reasonable doubt of rape with homicide because the State did not discharge its burden to prove beyond reasonable doubt every fact and circumstance constituting the crime charged.

Held:

No

Ratio:

The felony of rape with homicide is a composite crime. A composite crime, also known as a special complex crime, is composed of two or more crimes that the law treats as a single indivisible and unique offense for being the product of a single criminal impulse. It is a specific crime with a specific penalty provided by law, and differs from a compound or complex crime under Article 48 of the Revised Penal Code.

There are distinctions between a composite crime, and a complex or compound crime under Article 48 RPC. In a composite crime, the composition of the offenses is fixed by law; in a complex or compound crime, the combination of the offenses is not specified but generalized, that is, grave and/or less grave, or one offense being the necessary means to commit the other. For a composite crime, the penalty for the specified combination of crimes is specific; for a complex or compound crime, the penalty is that corresponding to the most serious offense, to be imposed in the maximum period. A light felony that accompanies a composite crime is absorbed; a light felony that accompanies the commission of a complex or compound crime may be the subject of separate information.

Supreme Court conceded the difficulty of proving the commission of rape when only the victim is left to testify on the circumstances of its commission; because in the crime is rape with homicide, because there may usually be no living witnesses if the rape victim is herself killed. Yet, the situation is not always hopeless for the State, for the Rules of Court also allows circumstantial evidence to establish the commission of the crime as well as the identity of the culprit.  Direct evidence proves a fact in issue directly without any reasoning or inferences being drawn on the part of the factfinder; in contrast, circumstantial evidence indirectly proves a fact in issue, such that the factfinder must draw an inference or reason from circumstantial evidence.  To be clear, then, circumstantial evidence may be resorted to when to insist on direct testimony would ultimately lead to setting a felon free.

The Rules of Court makes no distinction between direct evidence of a fact and evidence of circumstances from which the existence of a fact may be inferred; hence, no greater degree of certainty is required when the evidence is circumstantial than when it is direct. In either case, the trier of fact must be convinced beyond a reasonable doubt of the guilt of the accused.  Nor has the quantity of circumstances sufficient to convict an accused been fixed as to be reduced into some definite standard to be followed in every instance.