Facts:

The case involves Mario A. Bravo, the accused-appellant, who was convicted of murdering his mother-in-law, Elena Sta. Maria, by the Regional Trial Court of Malolos, Bulacan. The incident occurred on June 28, 1989, at their residence in Caingin, San Rafael, Bulacan. The prosecution presented six witnesses, including Bravo's wife, Teofila, and their 11-year-old daughter, Mary Joy. The prosecution's narrative revealed that Mary Joy was studying in the living room while her grandmother was in the kitchen and her father was in the yard. After hearing a commotion and her grandmother's scream, Mary Joy found her father with his hands on her grandmother's head, who was lying on the floor.

Mary Joy ran to fetch her other grandmother, Natividad Sta. Maria, who arrived to find Mario choking Elena, who was bleeding and pale. Natividad attempted to assist Elena, who, before dying, accused Mario of attacking her, stating, "Pinalo ako ni Mario." Neighbors helped...

Facts:

Incident Overview

• Mario Bravo, the accused-appellant, was charged with the murder of his mother-in-law, Elena Sta. Maria. He claimed her death was accidental, but the trial court convicted him of murder.

Prosecution's Version

• Witnesses: The prosecution presented six witnesses, including Bravo's wife (Teofila), his 11-year-old daughter (Mary Joy), Natividad Sta. Maria (Elena's sister), Luisito Sta. Maria (Elena's nephew), Maxima Rodriguez (a neighbor), and Dr. Benito Caballero (the autopsy surgeon).
• Events: On June 28, 1989, Mary Joy was studying in their house in Caingin, San Rafael, Bulacan. Her grandmother, Elena, was in the kitchen, and her father, Mario, was in the yard. Mario instructed Mary Joy to go to the bedroom and ignore any noises. Shortly after, Mary Joy heard a scuffle and her grandmother's scream. She found Mario in the kitchen with his hands on Elena's head. Elena was lying on the floor, bleeding.
• Response: Mary Joy ran to fetch Natividad Sta. Maria, who arrived to find Mario choking Elena. Natividad intervened and helped carry Elena to a bed. Elena stated, "Pinalo ako ni Mario. May tama rin ako sa dibdib" (Mario hit me. I was also hit in the chest). Elena was taken to the hospital but died the same day.
• Autopsy Report: Dr. Caballero determined the cause of death as "shock due to cerebral hemorrhage and brain concussion with internal hemorrhage, fractured ribs, ruptured lungs, and pericardium due to multiple traumatic force in the head, neck, extremity, shoulder, and chest."

Defense's Version

• Mario claimed Elena's injuries resulted from a fall in the kitchen. He denied any involvement in her death and suggested that prosecution witnesses had ulterior motives for testifying against him.

Trial Court's Decision

• Judge Agustin S. Dizon found Mario guilty of murder and sentenced him to reclusion perpetua, with civil indemnity of P30,000 to Elena's heirs.

Issue:

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Ruling:

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Ratio:

1. Credibility of Witnesses:

   • The Court found Mary Joy's testimony credible, especially since she testified against her own father. Her account was corroborated by Natividad Sta. Maria and other witnesses.
   • Elena's statements ("Pinalo ako ni Mario") were considered dying declarations and part of the res gestae, as they were made under the consciousness of impending death and immediately after the incident.

2. Defense's Version Rejected:

   • The Court dismissed Mario's claim that Elena's injuries resulted from a fall. Dr. Caballero's testimony confirmed that the injuries were caused by multiple traumatic forces, inconsistent with a simple fall.
   • The absence of a weapon was not fatal to the prosecution, as the injuries could have been inflicted with Mario's hands.

3. Motive:

   • While motive is not essential when the accused is positively identified, testimonies revealed that Mario often quarreled with Elena, providing additional context for the crime.

4. Constitutional Issue:

   • The Court ruled that the trial court's decision complied with constitutional requirements. The judge's selective presentation of facts was necessary to separate relevant evidence from irrelevant claims.

5. Qualifying Circumstance:

   • The crime was qualified as murder due to abuse of superior strength, as Mario, a 43-year-old man, inflicted fatal injuries on the 80-year-old Elena.

Conclusion:

• The Supreme Court upheld Mario Bravo's conviction for murder, emphasizing the credibility of the prosecution's witnesses and the implausibility of the defense's version. The civil indemnity was increased to P50,000 in line with the Court's policy.