**Facts:**
Conrado Laog was charged before the Regional Trial Court (RTC), Branch 11, of Malolos, Bulacan, with murder (Criminal Case No. 2162-M-2000) and rape (Criminal Case No. 2308-M-2000). The cases were jointly tried as they originated from the same incident on June 6, 2000. Laog pleaded not guilty to both charges.
The prosecution’s main witness, the rape victim (AAA), testified that she and Jennifer Patawaran-Rosal were attacked by Laog while walking to apply for work. Laog, armed with a lead pipe and an ice pick, forcibly brought them to a grassy area, where he assaulted them. He struck AAA and Jennifer with the lead pipe, knocked them down, stabbed Jennifer several times with the ice pick, and covered her body with thick grass. Laog then raped AAA and similarly covered her with grass. AAA regained consciousness later, sought help, and was subsequently hospitalized. Jennifer’s body was found covered with grass and already decomposing.
Laog, the defense, claimed he was at home during the crime, witnessed by his children and a nephew. He admitted prior interactions with the victims but denied the crimes.
After the trial, the RTC found Laog guilty of both murder and rape, resulting in sentences of Reclusion Perpetua and orders to pay damages. Laog appealed to the Supreme Court after the Court of Appeals affirmed the RTC’s ruling.
**Issues:**
1. Credibility of the prosecution witness, AAA.
2. Failure of the prosecution to prove guilt beyond a reasonable doubt.
3. Ownership of the fatal initiation of the crimes charged.
4. Proper categorization of the crimes committed: whether these constitute separate offenses of rape and murder or the special complex crime of rape with homicide.
**Court’s Decision:**
The Supreme Court dismissed Laog’s appeal, affirming the conviction with modifications. It judged that Laog’s defense of denial and alibi could not trump AAA’s positive identification and testimony. The Court found AAA’s account credible and consistent, ruling out any ill motive for false testimony.
The Court reclassified the crimes to the special complex crime of rape with homicide under Article 266-B of the Revised Penal Code, considering the proven facts that both rape and killing were committed by Laog, veering from the separate charges of murder and rape. The Court sentenced Laog to reclusion perpetua without eligibility for parole, modifying damages awarded for consistency with jurisprudence and pertinent laws.
**Doctrine:**
The Supreme Court underscored that the positive identification and categorical testimony of a rape victim take precedence over a defendant’s denial and alibi. Additionally, it elucidated that rape with homicide is a special complex crime under Article 266-B, reflecting that its prosecution necessitates proving each component offense as if they were subject to separate complaints.
**Class Notes:**
– Defense of Denial and Alibi: Positively identified by credible witness testimony is superior to denial and alibi, especially without substantial proof.
– Rape With Homicide as a Special Complex Crime: Under Article 266-B of the Revised Penal Code, the crime is classified as rape with homicide if during or on the occasion of rape, a homicide occurs.
– Exemplary Damages: Awarded also in recognition of aggravated circumstances proven during the trial and for reprehensible conduct of the offender, under Articles 2229 and 2230 of the Civil Code.
**Historical Background:**
The case exemplifies the legal principles surrounding the credibility of witness testimonies, particularly in heinous crimes such as rape and homicide, and showcases the jurisprudential evolution regarding the classification and prosecution of special complex crimes within the Philippine legal system.
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