People v. Sevilleno
REITERATIONFacts
The Antecedents: On July 25, 1995, appellant Paulino Sevilleno y Villanueva was charged with rape with homicide for the incident that occurred on July 22, 1995, involving a 9-year-old victim, Virginia Bakia. The Information alleged that the appellant, by means of force, violence, and intimidation, had carnal knowledge of the victim against her will and subsequently strangled her to death to conceal his identity and prevent discovery. Procedural History: Upon arraignment, the appellant entered a guilty plea. However, the trial court failed to conduct a searching inquiry into the voluntariness and comprehension of the plea. The appellant also escaped during the proceedings but was recaptured. The Regional Trial Court (RTC) of San Carlos City, Negros Occidental, Branch 57, found him guilty and sentenced him to death. On automatic review, the Supreme Court found the initial proceedings flawed due to the lack of a proper inquiry into the guilty plea and the defense counsel's remissness. The decision was set aside, and the case was remanded for proper arraignment and trial. The appellant was re-arraigned on February 23, 2000, and pleaded not guilty. Trial on the merits ensued. The RTC of San Carlos City, Branch 59, on October 16, 2001, found the appellant guilty beyond reasonable doubt of rape with homicide and sentenced him to death, ordering him to pay civil indemnity, moral damages, and exemplary damages. The case was elevated to the Supreme Court for automatic review. The Petition: The appellant submitted two assignments of error: (I) the trial court erred in finding the extra-judicial confession valid and binding, and (II) the trial court erred in finding his guilt for rape with homicide proven beyond reasonable doubt.
Issue(s)
Whether the extra-judicial confession executed by the appellant is valid and binding. Whether the guilt of the accused-appellant for the crime of rape with homicide has been proven beyond reasonable doubt.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court finding the appellant guilty beyond reasonable doubt of the crime of Rape with Homicide, and imposing upon him the penalty of DEATH. The Court modified the damages awarded, ordering the appellant to pay the heirs of Virginia Bakia P100,000.00 as civil indemnity and P75,000.00 as moral damages, while deleting the award of P25,000.00 as exemplary damages for lack of legal basis.
Ratio Decidendi
On the validity and binding effect of the extra-judicial confession: The Court found the appellant's contention that his extra-judicial confession was invalid misleading. The Supreme Court Resolution cited by the appellant pertained to the defense lawyer's participation during the arraignment, not the custodial investigation. The confession was executed in the presence of Atty. Vicente J. Agravante, who was the appellant's personally chosen counsel and had previously represented him. The Court reiterated the rule that once the prosecution shows compliance with constitutional requirements during custodial investigations, a confession is presumed voluntary, and the declarant bears the burden of proving otherwise. The appellant failed to show that his confession was given under duress, intimidation, threat, or promise of reward. Atty. Agravante testified that the appellant was informed of his constitutional rights, understood them, and voluntarily confessed his guilt. The appellant's claim that his confession bore only a thumbprint was not an indication of irregularity, especially since it was executed in the presence of his lawyer. Furthermore, the conviction was not based solely on the confession but on other established pieces of evidence. On whether the guilt of the accused-appellant for the crime of rape with homicide has been proven beyond reasonable doubt: The Court affirmed the trial court's conviction based on a totality of circumstantial evidence. These circumstances included: (1) the victim and her sister being seen in the company of the appellant prior to the crime; (2) the appellant inviting the victim to watch a "beta-show" in Sitio Guindali-an; (3) Norma Bakia seeing the appellant and the victim proceed towards a sugarcane field where the victim's corpse was later found; (4) Maria Lariosa seeing the appellant and the victim pass by her house en route to the sugarcane field; (5) Maria Lariosa seeing the appellant emerge alone from the sugarcane field with fresh scratches on his face, neck, and arms; (6) Norma Bakia observing scratch marks on the right side of the appellant's face and neck when he visited their house; (7) the victim's body being found in the same sugarcane field; (8) the multiple scratches on the appellant's face and ears being caused by human fingernails; and (9) the appellant being the last person seen with the victim. The appellant's explanation that the scratches were caused by a galvanized sheet was contradicted by prosecution witnesses who testified that the appellant admitted they were inflicted by the victim or his girlfriend. The defense of denial is inherently weak and requires strong corroborating evidence, which was absent. The alibi presented by the appellant also lacked credible corroboration from disinterested witnesses, and it was not impossible for him to be at the crime scene. The Court emphasized that direct evidence is not a sine qua non for conviction, and circumstantial evidence, when forming an unbroken chain leading to the conclusion of the appellant's guilt to the exclusion of all others, is sufficient.
Main Doctrine
The totality of circumstantial evidence, including the appellant being the last person seen with the victim, the victim's body being found in the place where they were last seen together, and the appellant's inconsistent explanations for injuries sustained, can establish guilt beyond reasonable doubt for rape with homicide, even in the absence of direct evidence. Denial and alibi are weak defenses when not corroborated by strong evidence.