People v. Bascugin
REITERATIONFacts
The Antecedents: Accused-appellant Leodegario Bascugin was charged with rape with homicide for an incident that occurred on June 4, 1999. The victim, AAA, was last seen by a tricycle driver, de Mesa, around 7:00 p.m. boarding Bascugin's tricycle. Another witness, Liwanag, heard a girl shout near where Bascugin's tricycle was parked around 8:30 p.m. AAA was reported missing around 11:50 p.m. Police found Bascugin at a hospital with a tongue injury. He claimed AAA was his passenger, but two other individuals boarded, and he lost consciousness after being hit, waking up with an injured tongue and his passengers gone. Later, police found AAA's body in a canal, naked from the waist down, with multiple stab wounds. Her hairclip was found near the waiting shed where Bascugin's tricycle was parked. Procedural History: Bascugin initially pleaded guilty and was sentenced to death by the RTC. This Court annulled the judgment due to an invalid arraignment and remanded the case. On re-arraignment, Bascugin pleaded not guilty. The prosecution adopted previous testimonies and presented additional witnesses. Later, Bascugin moved to change his plea to guilty, which was accepted, and he admitted to raping and killing AAA. However, he subsequently moved to withdraw his guilty plea, which was granted, and he pleaded not guilty again. During trial, Bascugin testified, admitting to raping and killing AAA, citing remorse and a bothered conscience as reasons for his changing pleas. The RTC found him guilty of rape with homicide and imposed the death penalty. The CA affirmed the conviction but modified the penalty to reclusion perpetua without parole due to RA 9346, and increased moral damages while awarding temperate damages. The Petition: The accused-appellant appealed his conviction, arguing insufficient evidence of rape and that his confession should be expunged. The People, as plaintiff-appellee, sought to uphold the conviction.
Issue(s)
Whether the circumstantial evidence presented, coupled with the accused-appellant's judicial admission, was sufficient to prove his guilt beyond reasonable doubt for the crime of rape with homicide, and whether the accused-appellant's confession, made during his testimony, was valid and admissible as evidence despite his prior withdrawal of a guilty plea. Whether the damages awarded were proper and consistent with prevailing jurisprudence.
Ruling
The Supreme Court affirmed the Court of Appeals' decision with modification, ordering the accused-appellant to pay additional exemplary damages. The conviction for rape with homicide was upheld based on the accused-appellant's judicial admission and the corroborating circumstantial evidence. The penalty imposed was reclusion perpetua without eligibility for parole, along with civil indemnity, moral damages, temperate damages, and exemplary damages.
Ratio Decidendi
On the sufficiency of evidence and the admissibility of the confession: The Court held that the accused-appellant's admission during his testimony, where he affirmed under oath that he raped and killed AAA, constituted a judicial confession of a high order. This admission was freely, intelligently, and deliberately given, and was consistent with the established circumstantial evidence. The Court reiterated that a judicial confession is presumed to be prompted by truth and conscience, and under the Rules of Court, such admissions require no further proof and can be given in evidence against the party making them. The circumstantial evidence, including the victim being last seen with the accused, the discovery of the victim's belongings near where the accused's tricycle was parked, the presence of human blood on the accused's clothing matching the victim's blood type, and the medico-legal findings of sexual intercourse and stab wounds, collectively established the accused's guilt beyond reasonable doubt. The Court emphasized that circumstantial evidence is sufficient for conviction if there is more than one circumstance, the inference is based on proven facts, and the combination of all circumstances produces a conviction beyond reasonable doubt. The accused's prior withdrawal of a guilty plea did not render his subsequent judicial admission during trial inadmissible, as the latter was made under oath and in the course of the proceedings, affirming his responsibility for the crime. On the damages awarded: The Court affirmed the appellate court's award of P100,000.00 as civil indemnity and P75,000.00 as moral damages, consistent with prevailing jurisprudence for rape with homicide. It also upheld the award of P25,000.00 as temperate damages in lieu of actual damages, recognizing that expenses for burial and wake are reasonably expected. Additionally, the Court awarded P50,000.00 as exemplary damages, citing Article 2229 of the Civil Code, which allows for such damages to deter the commission of similar acts and to mold behavior with grave and deleterious consequences to society.
Main Doctrine
A judicial confession, freely, intelligently, and deliberately given, constitutes evidence of a high order, and when consistent with the evidence on record, is sufficient to support a conviction beyond reasonable doubt. Circumstantial evidence is sufficient for conviction if there is more than one circumstance, the inference is based on proven facts, and the combination of all circumstances produces a conviction beyond reasonable doubt.