Case Digest (G.R. No. 179382)
Facts:
On May 26, 2014, at the residence of Lolo Harry in Tiwitiw, Banangan, Municipality of Sablan, Province of Benguet, three‐year‐old Jeana Rose Argayan Mangili (“Jeana”) was found with multiple stab wounds on her back and fatal hack wounds on her head. Present were her mother, Diane Argayan y Ognayon (“Diane”), and her cousin Raven Rhyzl Cha-ong (“Raven”), then six years old. Raven left Jeana and Diane alone for a time while harvesting pechay in the garden. Upon returning, Raven discovered Jeana bleeding with a knife in her back. Jeana identified her mother as her attacker. Diane removed the knife, treated and bathed Jeana, washed her clothes, and later asked Raven to return to the garden, again leaving Jeana unguarded. When Raven next checked, Jeana lay lifeless on the kitchen floor. Senior Police Officer Nixon P. Banasen and Police Officer Wilfredo P. Sabas arrived, documented the scene, and recovered broken bottles and a kitchen knife with a black handle. The body was brought toCase Digest (G.R. No. 179382)
Facts:
- Parties and Charge
- The People of the Philippines (plaintiff-appellee) charged Diane Argayan y Ognayon (accused-appellant) with parricide by Information dated July 7, 2014.
- The Information alleged that on May 26, 2014, at Tiwitiw, Banangan, Sablan, Benguet, Diane willfully stabbed her daughter Jeana Rose Argayan Mangili, inflicting multiple fatal wounds.
- Trial Proceedings
- Diane pleaded not guilty upon arraignment; trial on the merits ensued after pre-trial.
- Prosecution presented testimony of six-year-old Raven Rhyzl Cha-ong, who witnessed her cousin Jeana bleeding with a knife in her back, and who identified Diane as the assailant.
- Scene investigators documented broken bottles, photographed the crime scene, and collected evidence.
- Medico-legal officer Dr. Jaime Rodrigo Leal conducted autopsy revealing six hack wounds on the head and seven stab wounds on the back; cause of death was hemorrhagic shock.
- Raven’s sworn statement described the kitchen knife with a black handle as the weapon.
- Social Welfare Officer Girlie Willie testified that Diane, in private counseling sessions, admitted killing her daughter.
- Diane waived her right to present defense evidence.
- Lower Court Decisions
- The RTC (Branch 9, La Trinidad, Benguet) found all elements of parricide proven, credited Raven’s testimony, and held Diane of sound mind. It sentenced her to reclusion perpetua and awarded civil, moral, and exemplary damages of PHP 75,000 each, plus interest.
- On appeal, the Court of Appeals (Second Division) affirmed the RTC, emphasizing Raven’s consistent testimony, Diane’s conduct at the scene, and her extrajudicial admission as corroborative evidence.
- Supreme Court Proceedings
- Diane elevated the case to the Supreme Court, arguing lack of direct evidence that she killed Jeana and inadmissibility of her unwritten admission.
- The Office of the Solicitor General maintained that the prosecution proved all elements and that Diane’s extrajudicial confession complied with constitutional safeguards and was admissible.
Issues:
- Whether the Court of Appeals erred in affirming Diane’s conviction for parricide given the absence of direct evidence and the allegedly inadmissible extrajudicial admission.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)