People v. Remollo
REITERATIONFacts
The Antecedents: On the evening of April 27, 1991, in Barangay Cancawas, San Jose, Negros Oriental, six-year-old Maryjin Superal was brought by her father to a drinking party at the house of the appellant Saturnino Remollo's parents. The appellant, an uncle of the victim, took Maryjin to the kitchen to eat. Later, the victim's father went home, believing his daughter had preceded him. The victim was not seen again by her father. The following morning, the victim's dead body was discovered near a blackberry tree, approximately 100 meters from the appellant's house. Procedural History: A post-mortem examination revealed that the victim died of asphyxia due to strangulation. The examination also indicated that sexual intercourse had occurred, evidenced by spermatozoa found in the vagina and a lacerated hymen, consistent with penetration by a penis. The municipal health officer noted the vaginal orifice was abnormally large for a child of that age. Two young nephews of the appellant testified that the appellant confessed to killing Maryjin and warned them not to tell anyone. The appellant offered an alibi, claiming he was at a dance in San Jose during the commission of the crime. The Regional Trial Court of Dumaguete City found the appellant guilty of the complex crime of rape with homicide and sentenced him to reclusion perpetua, ordering him to pay civil indemnity, exemplary damages, and moral damages to the heirs of the victim. The Petition: The accused-appellant appealed the decision, arguing that the trial court erred in giving credence to the testimonies of the prosecution witnesses (his nephews), admitting his extrajudicial confession obtained in violation of his constitutional rights, and convicting him despite insufficient proof of guilt beyond reasonable doubt.
Issue(s)
Whether the testimonies of the prosecution witnesses, nephews of the appellant, were credible. Whether the extrajudicial confession of the appellant was admissible in evidence, considering alleged violations of his constitutional rights. Whether the circumstantial evidence, independent of the confession, was sufficient to prove guilt beyond reasonable doubt. Whether the alibi of the appellant was tenable.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the accused-appellant guilty of the complex crime of rape with homicide. The Court sentenced him to suffer the penalty of reclusion perpetua and ordered him to pay damages to the heirs of the victim. The award for moral damages was reduced.
Ratio Decidendi
On the credibility of the prosecution witnesses: The Court held that the trial court did not commit a serious error in giving weight and credence to the testimonies of the prosecution witnesses, Angelito Remollo and Eddie Singco, who were the appellant's nephews. The Court emphasized the familiar rule that the assessment of the trial court regarding the sincerity and credibility of witnesses is accorded great respect by appellate courts. The appellant failed to demonstrate any motive or evil intent on the part of the young witnesses to falsely testify against him. Their statements were considered straightforward and candid, and there was no evidence suggesting they would fabricate a story implicating their uncle in such a heinous crime. The Court noted that the witnesses, despite their young age, provided consistent accounts and their relationship with the appellant did not automatically render their testimonies unbelievable. On the admissibility of the extrajudicial confession: The Court found no merit in the appellant's claim that his extrajudicial confession was inadmissible. The appellant alleged that he signed the statement in English, a language he did not understand, and that it was not translated. However, the lawyer who assisted him testified that the statement was read to him in English and then translated into Visayan. Furthermore, the confession itself stated that the appellant was informed of his constitutional rights, understood them, and waived them. Police officers and the assisting lawyer corroborated that the appellant was apprised of his rights before the investigation. The Court also dismissed the claim of coercion due to an intimidating atmosphere, noting that the confession was signed in the presence of his mother, sister, nephews, and counsel, which made police brutality unlikely. The appellant's failure to present his mother or sister to testify about coercion further weakened his claim. The Court also addressed the appellant's contention that his counsel of choice was not respected, explaining that while the initial choice of counsel may be by the police, the accused has the final choice and can reject the appointed counsel. In this case, the appellant affirmatively accepted the assistance of Atty. Renacia, and his subsequent complaint during trial was deemed too late. On the sufficiency of circumstantial evidence: The Court ruled that even if the extrajudicial confession were to be rejected, the circumstantial evidence on record was sufficient to support a finding of guilt beyond reasonable doubt. The Court enumerated several circumstances: the appellant was the last person seen with the victim alive; he took the victim with him to the kitchen and later went down his parents' house with the victim following him; he spontaneously confessed to his nephews that he had killed Maryjin and threatened them; and he admitted to his mother in the presence of others that he had killed the child. These circumstances, when taken together, pointed to the appellant's guilt. On the defense of alibi: The Court found the appellant's alibi to be untenable. The appellant claimed he was at a dance in San Jose, which was only about 15 minutes away from his house by foot. Crucially, he failed to present his alleged companions to corroborate his alibi. Moreover, he testified to taking a bath in a river only 500 arm-lengths from where the victim's body was found, contradicting his claim of impossibility of being at the scene of the crime. The Court reiterated that for an alibi to prosper, the accused must not only prove he was elsewhere but also that it was impossible for him to be at the scene of the crime.
Main Doctrine
The Court affirmed the conviction for the complex crime of rape with homicide, holding that the circumstantial evidence, independently of the extrajudicial confession, was sufficient to prove guilt beyond reasonable doubt. The Court also upheld the admissibility of the confession, finding that the accused was properly informed of his rights and voluntarily executed the statement with the assistance of counsel.