Case Digest (G.R. No. 255750)
Facts:
People of the Philippines v. Diane Argayan y Ognayon, G.R. No. 255750, January 30, 2023, Supreme Court Second Division, Lopez, J., writing for the Court.On July 7, 2014, an Information charged Diane Argayan y Ognayon (accused-appellant) with parricide for allegedly stabbing and hacking to death her three‑year‑old daughter, Jeana Rose Argayan Mangili, on or about May 26, 2014 in Sablan, Benguet. Diane pleaded not guilty at arraignment. After pre‑trial and trial on the merits, the prosecution presented eyewitness and forensic proof while the accused waived her right to present evidence.
The prosecution’s core factual narrative emerged chiefly from the testimony of six‑year‑old Raven Rhyzl Cha‑ong, who said she last saw Diane and Jeana together at the pechay garden, left Jeana with Diane when she briefly went to the garden, and upon returning found Jeana crying with a kitchen knife embedded in her back; according to Raven, Jeana said her mother stabbed her. Police officers arriving on the scene recovered a bloodied body; photographs and a sketch were taken. The medico‑legal officer, Dr. Jaime Rodrigo Leal, testified and produced a medico‑legal report showing multiple fatal hack wounds to the head and multiple stab wounds to the back; cause of death was hemorrhagic shock secondary to those injuries.
A social welfare officer, Girlie O. Willie, assisted in taking Raven’s sworn statement and later testified as to repeated visits to Diane to provide counseling; Girlie testified that Diane, in the course of those visits, admitted she killed Jeana. Diane waived presentation of defenses and did not introduce evidence on her mental state. The Regional Trial Court (RTC), Branch 9, La Trinidad, Benguet, found Diane guilty beyond reasonable doubt of parricide in a May 10, 2018 Decision, gave full credence to Raven’s testimony, treated Girlie’s testimony about Diane’s admission as corroborative evidence, and sentenced Diane to reclusion perpetua and ordered damages.
Diane appealed to the Court of Appeals (CA), which in CA‑G.R. CR HC No. 11369 affirmed the RTC in a September 24, 2020 Decision, finding the extrajudicial admission admissible as corroborative and that the circumstantial facts and medico‑legal findi...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in affirming the conviction of Diane Argayan y Ognayon for parricide?...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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