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
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 ...view middle of the document...
The Court of Appeals also affirmed the conviction.
The accused appealed and argued that both RTC and CA erred in convicting him of a composite crime of Rape with homicide through circumstantial evidence.
Can the accused be convicted of a composite crime of rape with homicide through circumstantial evidence?
YES. In order to convict Villaflores for the composite crime of rape with homicide, the State must thus prove the concurrence of the following facts, namely: (a) that Villaflores had carnal knowledge of Marita; (b) that he consummated the carnal knowledge without the consent of Marita; and (c) that he killed Marita by reason of the rape.
Under the RPC as amended, rape is always committed when the accused has carnal knowledge of a female under 12 years of age. The crime is commonly called statutory rape, because a female of that age is deemed incapable of giving consent to the carnal knowledge. Marita’s Certificate of Live Birth disclosed that she was born on October 29, 1994, indicating her age to be only four years and eight months at the time of the commission of the crime on July 2, 1999. As such, carnal knowledge of her by Villaflores would constitute statutory rape....