CASE DIGEST
People v. Leocadio y
Labrador
G.R. No. 227396, [February 22, 2023]
SECOND, LOPEZ, M.V
Rape with Homicide; Exempting Circumstance of Accident; Circumstantial Evidence of Guilt
The court emphasized that for accident
to be considered an exempting circumstance, there must be a complete absence of
intent or negligence on the part of the accused. In this case, the court upheld
the conviction based on circumstantial evidence, that constitute an unbroken
chain of events leading to one fair and reasonable conclusion, that points to
the accused's guilt to the exclusion of all others. Despite the absence of
direct witnesses to the crime, the court found the circumstantial evidence
presented by the prosecution to be sufficient for conviction.
On March 26, 2002, AAA, a 12-year-old girl, was sent by her parents, BBB and CCC, to collect payment from their neighbor, Milo Leocadio y Labrador (Milo), for rice cakes. AAA did not return home, causing her parents to search for her. The next day, they reported her disappearance to the police. It was later discovered that AAA's lifeless body was found in Milo's house. She was found under Milo's bed with a cloth wrapped around her mouth and nose, hands tied behind her back, and signs of sexual assault and multiple injuries.
During the trial, Milo admitted to killing AAA but claimed it was accidental. He stated that he was sleeping when AAA suddenly touched his shoulder, causing him to unconsciously throw a punch that led to her death. Milo denied any sexual assault and maintained that he did not rape AAA. He asserted that the injuries sustained by the victim were caused by a single blow he delivered, which led to her accidental death.
Whether or not Milo is guilty beyond reasonable doubt of the complex crime of rape with homicide.
YES.
The Court affirms the decision finding Milo guilty of rape with homicide.
Despite Milo's claim of accidental killing, the circumstances do not support
the exemption from criminal liability due to accident. The court emphasized
that accident requires the absence of intent or negligence on the part of the
accused, and Milo's actions did not meet this standard.
In crimes against persons, such as rape with
homicide, the intent to kill is presumed if the victim dies as a result of a
deliberate act of the perpetrator. The court noted that AAA's death, caused by
asphyxia and multiple injuries, indicated a deliberate and intentional act by
Milo. The extent and nature of the injuries sustained by the victim suggested
an intent to kill, which belies Milo's claim of accidental killing.
The defense of accident is struck down due to Milo's failure to establish it with clear and convincing proof. Additionally, circumstantial evidence convincingly links Milo to the rape and murder of AAA. In this case, the prosecution presented a chain of events and medical findings that pointed to Milo's guilt. Despite the absence of direct witnesses to the rape and murder, the circumstantial evidence, including AAA's disappearance after visiting Milo's house and the nature of her injuries, formed a solid basis for conviction. Hence, Milo is sentenced to suffer reclusion perpetua without parole and ordered to pay various damages to the victim's heirs with legal interest.
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