PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. VICENTE VALLA, ACCUSED-APPELLANT.

People versus Valla

The Case

This is the People of the Philippines against Vicente Valla, a criminal appeal from a conviction for the special complex crime of rape with homicide. The accused was charged with having raped and killed an eight-year-old girl, Dyesebel de la Cruz, in the ricefields of San Francisco, Quezon. The case matters to the reviewee for three reasons: it illustrates how the Supreme Court treats minor inconsistencies in witness testimony, it shows the interplay between an extrajudicial confession, the corpus delicti rule, and res gestae, and it fixes the correct civil liability in a rape with homicide case, including the effect of an aggravating circumstance on exemplary damages.

Procedural History

The accused was charged before the Regional Trial Court of Gumaca, Quezon, Branch 62, with rape with murder. Upon arraignment, assisted by counsel de oficio, he entered a plea of not guilty. After trial on the merits, the trial court rendered its decision on March 29, 1993, finding him guilty of rape with homicide, sentencing him to reclusion perpetua, and ordering him to pay the heirs of the victim 50,000 pesos as indemnity and 30,000 pesos as actual and moral damages. The accused appealed directly to the Supreme Court, assigning as errors the trial court's reliance on the testimonies of the prosecution witnesses and its finding of guilt despite what he claimed was insufficient evidence.

Facts

On the morning of April 14, 1991, a twelve-year-old girl, Myra Pines, was passing by a ricefield in Barangay Ilayang Tayuman, San Francisco, Quezon, carrying bananas. She heard a voice from the forested area that sounded like someone being strangled, and she recognized it as that of her friend and playmate, the eight-year-old Dyesebel de la Cruz. Frightened, Myra hurried to the crossing, delivered her bananas, and went home.

That afternoon, Dyesebel's mother reported to Barangay Captain Aristeo Allarey that her daughter was missing. The captain organized a search party of barangay officials, a barangay tanod, the victim's father Gonzalo de la Cruz, and other residents. The captain learned that Dyesebel had earlier been in the company of the accused, Vicente Valla, her cousin, who was twenty-eight years old, married, and a resident of the same barangay, and that both had been tasked to watch the ricefield. The accused was not there; he was reportedly drinking liquor in the house of a friend. The search stopped at around six-thirty in the evening because of darkness and resumed the following day, with the accused trailing behind the searchers.

At around eleven o'clock that morning, the body of Dyesebel was found near the river, her neck blackened and her vagina bloodied, her panty pulled down to her mid-thigh. Confronted by the captain and his companions, the accused admitted out of remorse that he had raped and killed the child, and in their presence he addressed the victim's father, offering his own daughter in payment for the life he had taken and begging for forgiveness. The father tried to draw his bolo but was restrained. The accused was arrested and brought to the police headquarters. The autopsy showed a depression on the skull from a hard object, blisters on the pubic area from contact with a lighted cigarette, and lacerations of the hymen indicative of repeated rape. In his defense, the accused denied the crime and interposed alibi, claiming he was at home caring for his sick child, corroborated by his father.

Issues

• Whether or not the trial court erred in giving full weight and credence to the testimonies of the prosecution witnesses despite the alleged inconsistencies.
• Whether or not the trial court erred in finding the accused guilty beyond reasonable doubt despite the alleged insufficiency of evidence, including his defense of alibi.
• Whether or not the accused is guilty of the special complex crime of rape with homicide.
• Whether or not the aggravating circumstance of ignominy should be appreciated.
• Whether or not the award of damages by the trial court was correct.

Applicable Provisions

Section 33 of Rule 130 of the Revised Rules of Court provides:

The declaration of a dying person, made under the consciousness of an impending death, may be received in any case wherein his death is the subject of inquiry, as evidence of the cause and surrounding circumstances of such death.

The Court cites this provision in holding that the accused's declaration acknowledging his guilt may be given in evidence against him.

Section 3 of Rule 133 of the Revised Rules of Court provides:

An extrajudicial confession made by an accused, shall not be sufficient ground for conviction, unless corroborated by evidence of corpus delicti.

This provision requires that the confession be corroborated by evidence of the corpus delicti, which the Court finds was satisfied in this case.

Section 42 of Rule 130 of the Revised Rules of Court provides:

Statements made by a person while a startling occurrence is taking place or immediately prior or subsequent thereto with respect to the circumstances thereof, may be given in evidence as part of the res gestae.

The Court applies this provision to the accused's plea for forgiveness and offer of his own daughter, made immediately after the discovery of the body.

Article 14, Number 17 of the Revised Penal Code provides:

That means be employed or circumstances brought about which add ignominy to the natural effects of the act.

The Court appreciates ignominy because the cigarette burns on the victim's pubic area added disgrace and obloquy to the material injury inflicted.

Article 2230 of the New Civil Code provides:

In criminal offenses, exemplary damages as a part of the civil liability may be imposed when the crime was committed with one or more aggravating circumstances.

This provision supports the award of exemplary damages in view of the attendance of one aggravating circumstance.

Ruling

On the first issue, the Court held that the alleged inconsistencies were too minor and insignificant to destroy the credibility of the prosecution witnesses. The discrepancy in the testimony of the barangay captain as to whether the accused immediately reported after being summoned, and the testimony that the accused was dazed at the time he admitted responsibility, referred only to collateral matters that did not touch upon the whys and wherefores of the crime. Inconsistencies on minor details do not impair credibility where there is consistency in relating the principal occurrence and in positively identifying the assailant; indeed, they may serve as badges of credibility, showing the witness was not coached. The barangay officials had no motive to falsely testify against their own townmate.

On the second issue, the Court rejected the defense of denial and alibi. The accused's house was in the same barangay as the scene, so there was no physical impossibility of his being present. His alibi was riddled with inconsistencies: he claimed only his wife and brother were with him, yet his father testified that he too was present, and the father first denied knowing the victim and later admitted knowing her. The Court held that the declaration of the accused acknowledging his guilt may be given in evidence against him, and that his extrajudicial confession was corroborated by the corpus delicti, which requires only some concrete evidence tending to show the commission of the crime apart from the confession, supplied here by the testimony of Myra Pines, the search party, and the medico-legal certificate. The plea for forgiveness and the offer of his own daughter were admissible as part of the res gestae.

On the third issue, the Court held that the trial court correctly convicted the accused of the special complex crime of rape with homicide, not rape with murder as designated in the Information, since homicide is taken in its generic sense.

On the fourth issue, the Court appreciated the aggravating circumstance of ignominy, given the cigarette burns on the victim's pubic area.

On the fifth issue, the Court corrected the damages. Civil indemnity of 100,000 pesos should be awarded, moral damages of 50,000 pesos without need of further proof, and exemplary damages of 20,000 pesos in view of one aggravating circumstance. Actual damages could not be allowed for lack of supporting evidence.

Doctrine

Minor inconsistencies in the testimony of witnesses, referring only to collateral details, do not impair their credibility where they are consistent on the principal occurrence and the positive identification of the assailant; the trial judge's assessment of credibility is accorded the highest respect and finality absent a weighty circumstance ignored or misunderstood.

An extrajudicial confession is not sufficient ground for conviction unless corroborated by evidence of the corpus delicti, which means only that there is some concrete evidence tending to show the commission of the crime apart from the confession; the Rules do not require that all the elements of the crime be established by evidence independent of the confession.

Statements made immediately after a startling occurrence, before the declarant had time to contrive a falsehood, and concerning the occurrence and its attending circumstances, are admissible as part of the res gestae.

In rape with homicide, the civil indemnity is 100,000 pesos, moral damages are 50,000 pesos without need of further proof, and exemplary damages of 20,000 pesos may be awarded when one aggravating circumstance attends the crime, pursuant to Article 2230 of the New Civil Code.

Disposition

The Supreme Court affirmed the conviction with modifications, sentencing Vicente Valla to reclusion perpetua and ordering him to pay the heirs of the victim 100,000 pesos as civil indemnity, 50,000 pesos as moral damages, and 20,000 pesos as exemplary damages, with costs against him.

Remember This

Memorize this line: minor inconsistencies on collateral matters are badges of credibility, not grounds to acquit, and an extrajudicial confession stands if corroborated by the corpus delicti. Examiners use this case to test the credibility rule, the res gestae requisites, and the correct damages in rape with homicide.