**Facts:**
1. **Initial Incident**: On September 16, 1997, at around 12:30 a.m., Helen Ramos discovered her eight-year-old daughter Nairube was missing from their home in Cavinti, Laguna. Helen noticed the backdoor was open and found a pair of muddy rubber slippers on a wooden bench.
2. **Discovery of the Body**: The search party, including the local police and townspeople, found Nairube’s body on September 18, 1997, in a grassy coconut plantation area known as Villa Anastacia. The body was in an advanced state of decomposition, and a medico-legal officer attributed the cause of death to hypovolemic shock secondary to vulvar laceration caused by penetration.
3. **Key Witness Statements**:
– **Violeta Cabuhat**: Testified seeing the accused at her house on September 15, 1997, late at night, intoxicated. He requested to sleep there, which she declined.
– **Loreto Veloria & Pedro Dela Torre**: Testified seeing the accused wearing a black collared T-shirt and the described slippers on the evening before Nairube’s disappearance.
– **Romualdo Ramos**: Saw the accused exiting Villa Anastacia around 8:30 a.m. on September 16, 1997, appearing drunk.
– **Alma Diaz & Helen Ramos**: Found a panty identified as belonging to Nairube near the crime scene.
4. **Statements and Confession**:
– **SPO2 Quirino Gallardo & Vice-Mayor Floro Esguerra**: Testified that the accused confessed to the crimes following his arrest, but these confessions were claimed to be made without the benefit of counsel and potentially under duress.
5. **Arrest and Procedural History**: The accused was arrested on the basis of the suspicion raised by the found slippers and other circumstantial evidence. The Regional Trial Court (RTC) of Santa Cruz, Laguna, convicted the accused of rape with homicide and sentenced him to death on October 8, 1998. The case automatically went to the Supreme Court for review due to the imposition of the death penalty.
**Issues:**
1. **Admissibility of the Confession**: Whether the confession made by the accused to the police and Vice-Mayor, allegedly without counsel and possibly under coercion, is admissible as evidence.
2. **Circumstantial Evidence**: Whether the circumstantial evidence presented (including the identification of slippers and T-shirt and the accused’s presence near the crime scene) is sufficient to convict the accused beyond reasonable doubt.
**Court’s Decision:**
1. **Confession**: The Supreme Court found that the accused’s confession was obtained without informing him of his rights to remain silent and to have counsel, and thus, violated Section 12, Article III of the Philippine Constitution. The confession was deemed inadmissible evidence.
2. **Circumstantial Evidence**: The Court held that the circumstantial evidence presented did not form an unbroken chain leading to the logical conclusion, to the exclusion of other hypotheses, that the accused was guilty. The slippers and T-shirt were considered insufficient to directly link the accused to the commission of the crime.
As a result, the Supreme Court reversed the RTC’s decision, acquitting the accused on the grounds of reasonable doubt and ordering his immediate release unless legally detained for another cause.
**Doctrine:**
Key doctrines reiterated include:
1. **Right to Counsel**: Any confession made without informing the accused of their rights to silence and counsel, or without the presence of counsel, is inadmissible.
2. **Circumstantial Evidence**: For a conviction based on circumstantial evidence, it must form an unbroken chain leading to a fair and reasonable conclusion pointing to the accused’s guilt to the exclusion of others.
**Class Notes:**
– **Elements of Rape with Homicide**: Rape resulting in the victim’s death constitutes a special complex crime of rape with homicide.
– **Right to Silence and Counsel**: Verbatim citation from Section 12, Article III of the Philippine Constitution about the rights of the accused.
– **Fruit of the Poisonous Tree Doctrine**: Any evidence derived from an inadmissible confession is likewise inadmissible.
– **Burden of Proof in Criminal Cases**: Emphasizes proof beyond reasonable doubt and that suspicions do not suffice for conviction (Rule 133 of the Rules on Evidence).
**Historical Background:**
This case highlights the rigorous standards required to uphold the death penalty in the Philippines. It underscores the judiciary’s role in safeguarding constitutional rights, particularly those protections against self-incrimination and coercion. The case reflects the stringent evidentiary standards necessary to secure a conviction, especially in capital cases, and sets a precedent in handling circumstantial evidence and confessions obtained without due process.
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