Case Digest (G.R. No. 235990)
Facts:
People of the Philippines v. Giralyn P. Adalia, G.R. No. 235990, January 22, 2020, Supreme Court First Division, Lazaro-Javier, J., writing for the Court.The prosecution charged Giraly n P. Adalia (accused-appellant) with infanticide under Article 255 of the Revised Penal Code for allegedly giving birth on or about July 17, 2010 and throwing the newborn girl—then less than three days old—into Arabe Creek, where the infant’s body, with umbilical cord and placenta intact, was recovered on July 20, 2010. The People of the Philippines was the plaintiff-appellee.
At arraignment appellant pleaded not guilty and she presented no witnesses or documentary evidence at trial. The prosecution presented testimonies from neighbors (Lorna Maruya, Esterlita Obera, Angelita Paltingca, Juanita Paclarin), police (PO3 Paquito Diaz), and Dr. Delia Futalan (Municipal Health Officer and Medico-Legal Officer). Their accounts described a visible progressive abdominal enlargement beginning late 2009/early 2010, admissions or statements by appellant suggesting pregnancy and an intention to “strangle” whatever she would give birth to, appellant’s bleeding and reduced abdominal size after July 17, the sound of a baby crying briefly in an abandoned shanty, bloodstained rags and freshly dug holes at the shanty, and discovery of a dead newborn in Arabe Creek whose condition suggested it had lived and died about two to three days earlier. Dr. Futalan examined the infant and later examined appellant (July 20, 2010), finding physical signs consistent with a recent vaginal delivery. The prosecution sought exhumation for DNA testing; appellant opposed; when ordered, the infant’s remains could not be located.
The Regional Trial Court (Branch 31, Dumaguete City) convicted appellant of infanticide by Decision dated February 23, 2016 and sentenced her to reclusion perpetua; the court concluded that although there was no direct eyewitness of the killing, the attendant circumstances established guilt beyond reasonable doubt. On appeal, the Court of Appeals affirmed in its Decision dated July 6, 2017 (CA-G.R. CR-HC No. 02210), modifying the penalty to state appellant was ineligible for parole and awarding P100,000 each for civil indemnity, moral and exemplary damages ...(Pro-only)
Issues:
- Did the Court of Appeals gravely err in affirming appellant’s conviction for infanticide based principally on circumstantial eviden...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)