G.R. No. 138403 Aug.

22, 2001
People vs Abulencia
Facts:
Rolly Abulencia was charged with rape with homicide before the Regional Trial
Court in Urdaneta City. The prosecution presented evidence that on August 4, 1998, the
victim's brother, Reynaldo Garcia, Jr., met Abulencia and they engaged in a drinking
spree. They later slept in Garcia's house, where the victim, Rebelyn Garcia, was also
present. Abulencia left the house in the afternoon to buy dilis, with Rebelyn following him.
They never returned. Abulencia later surrendered to the mayor, claiming that Rebelyn fell
from a bridge after he accidentally tripped her. The next morning, Rebelyn's dead body
was found floating in a creek. An autopsy revealed that she was sexually abused and
brutally killed. Abulencia admitted in a taped radio interview that he raped the victim.
Issue:
The main issue in the case is whether the circumstantial evidence presented is
sufficient to prove Abulencia's guilt beyond a reasonable doubt for the crime of rape with
homicide.
Ruling:
The court found that the trial court correctly relied on circumstantial evidence to
find Abulencia guilty. Circumstantial evidence can be as potent as direct evidence to
sustain a conviction if there is a concurrence of all the requisites prescribed in the rules
of evidence. In this case, the evidence presented established an unbroken chain of
circumstances pointing to Abulencia as the guilty person. His defense of Rebelyn
accidentally falling from the bridge was deemed highly preposterous and contrary to
common experience. The court also noted that Abulencia's defense was a mere denial,
which is intrinsically weak and must be buttressed by strong evidence of non-culpability,
which he failed to provide.