FACTS:

The case involves the brutal rape and killing of five-year-old Rowena C. Bangcong. The accused, Aldrin Licaya, was charged with Rape with Homicide. Prior to the incident, Licaya had been drinking with his friends, Bernard Agcopra and Romeo Bangcong. During the course of the evening, Licaya was observed embracing and kissing Rowena. When Rowena's brother witnessed this, he immediately informed their father. Concerned, a search party was formed to locate Rowena. Licaya was eventually arrested, with wet clothes and mud on his body. The following morning, Rowena's lifeless body was discovered in a nipa swamp, showing signs of physical abuse. Licaya was found guilty by the trial court and sentenced to death. However, Licaya managed to escape while in detention. Despite his escape, the trial court proceeded with the trial and rendered its judgment based on circumstantial evidence linking Licaya to the crime.

ISSUES:

1. Whether the circumstances presented by the prosecution are sufficient to prove the guilt of the accused-appellant.

2. Whether the witness's failure to shout upon finding the accused-appellant affects his credibility.

3. Whether the witnesses could have seen the accused-appellant in the darkness.

4. Whether the admission made by the accused-appellant to Jun-jun Dahilan is hearsay.

5. Whether the circumstances of accused-appellant being seen with wet pants, muddy body, and without slippers lack probative value.

6. Whether there were tell-tale signs that accused-appellant was dragging the victim.

7. Whether the statement made by Rogelio "Jun-jun" Dahilan, Jr. as to the location of the victim's body is hearsay.

8. Whether the statement made by accused-appellant regarding the location of the victim's body is an extra-judicial confession.

9. Whether the circumstantial evidence presented in the case is sufficient to establish the guilt of the accused beyond reasonable doubt.

10. Whether the penalty of death is the correct penalty to be imposed for the crime of rape with homicide.

11. Whether the awards of P50,000.00 as moral damages and P100,000.00 as civil indemnity are proper.

RULING:

1. The Supreme Court ruled that the circumstances presented by the prosecution, when taken together, constitute an unbroken chain leading to the conclusion that the accused-appellant is guilty. The court emphasized that the guilt of the accused cannot be deduced from scrutinizing just one particular piece of evidence; rather, it is the weaving of a tapestry of events that culminate in a clear picture pointing towards the accused as the author of the crime. The credibility of the witness who found the accused-appellant was not affected by his failure to shout, as different people react differently to such situations. The court also held that visibility, even in the dark, is a vital factor in identifying the perpetrator, and illumination produced by a flashlight or kerosene lamp is sufficient for identification. The fact that accused-appellant fled when spotted by the search party is considered as flight, which is taken as evidence of guilt. The admission made by accused-appellant to Jun-jun Dahilan is not hearsay and can be considered as evidence against him. Lastly, the circumstances of accused-appellant being seen with wet pants, muddy body, and without slippers have probative value in establishing his involvement in the crime. There were no tell-tale signs that accused-appellant was dragging the victim.

2. The statement made by Rogelio Dahilan, Jr. regarding the location of the victim's body is not hearsay. Any oral or documentary evidence is hearsay if its probative value is not based on the personal knowledge of the witnesses but on the knowledge of some other person. In this case, Rogelio Dahilan, Jr. testified that accused-appellant told him where the victim's body can be found, and the victim's body was actually recovered at the location pointed by accused-appellant.

3. The statement made by accused-appellant regarding the location of the victim's body is not an extra-judicial confession. It is an extra-judicial admission. A confession is an acknowledgment by a party in a criminal case of his guilt of the crime charged, while an admission is a statement by the accused of facts pertinent to the issue and tending to prove his guilt. In this case, accused-appellant's statement only acknowledged the location of the victim's body but did not explicitly admit to his guilt.

4. The court finds that the circumstantial evidence presented in the case, when viewed in its entirety, is as convincing as direct evidence and negates the innocence of the accused. The circumstantial evidence fully justifies the finding of the accused's guilt beyond reasonable doubt of the crime of rape with homicide.

5. The penalty of death is the correct penalty to be imposed for the crime of rape with homicide. Death is a single indivisible penalty and must be mandatorily imposed regardless of any mitigating or aggravating circumstance.

6. The award of P50,000.00 as moral damages is proper considering the pain and anguish brought about by the victim's death. The amount of P100,000.00 as civil indemnity is also proper in accordance with prevailing jurisprudence.

PRINCIPLES:

• Circumstantial evidence - A judgment of conviction based on circumstantial evidence can be upheld if the circumstances proved constitute an unbroken chain which leads to one fair and reasonable conclusion pointing to the accused to the exclusion of all others, as the guilty person.

• Credibility of witnesses - Different people react differently to a given stimulus or type of situation, and there is no standard form of behavioral response when one is confronted with a strange, startling, or frightful experience.

• Identification of persons - Visibility is a vital factor in determining whether an eyewitness could have identified the perpetrator of a crime. Even with illumination produced by a flashlight or kerosene lamp, identification of persons is possible.

• Flight as evidence of guilt - The unexplained flight of the accused may be taken as evidence having a tendency to establish guilt. Flight is an indication of guilt.

• Admissions - The act, declaration, or omission of a party as to a relevant fact may be given in evidence against him. Flight, in criminal law, means an act of evading the course of justice by voluntarily withdrawing oneself to avoid arrest or detention or the institution or continuance of criminal proceedings.

• Hearsay: Any oral or documentary evidence is hearsay if its probative value is not based on the personal knowledge of the witnesses but on the knowledge of some other person. The opportunity to cross-examine the witness negates the claim that the evidence is hearsay.

• Extra-judicial confession: A confession is an acknowledgment in express terms, by a party in a criminal case, of his guilt of the crime charged. An extra-judicial admission, on the other hand, is a statement by the accused, direct or implied, of facts pertinent to the issue and tending, in connection with proof of other facts, to prove his guilt.

• Corpus delicti: An extra-judicial confession shall not be sufficient ground for conviction unless corroborated by evidence of corpus delicti. Corpus delicti refers to the body of the crime and means that a crime has actually been committed.

• Voluntariness of confession: The voluntariness of a confession may be inferred from its language. If the confession exhibits no suspicious circumstances and is replete with details that could only be supplied by the accused, reflecting spontaneity and coherence, it can be considered voluntary.

• Identification of the accused: Direct evidence is not always necessary to identify the accused as the perpetrator of the crime. Circumstances can also be considered in determining the accused's guilt.

• Circumstantial evidence can be as convincing as direct evidence and may sufficiently establish the guilt of the accused beyond reasonable doubt.

• The penalty for the crime of rape with homicide is death, which must be mandatorily imposed regardless of any mitigating or aggravating circumstance.

• The award of moral damages and civil indemnity in cases of rape with homicide is proper to compensate the pain and anguish of the victim's family.