G.R. No. 129895 - People vs. Dalag

Appellant PO3 Armando Dalag, a police officer, was married to Leah Nolido Dalag; they had three children—Francis, Princess Joy, and Ezra John—and lived in Bacolod City.
Their marriage was characterized by violent quarrels, during which Leah often sustained physical injuries inflicted by Armando.

On the evening of August 15, 1996, children Francis (eleven) and Princess Joy (nine) witnessed their parents drinking and quarreling under a datiles tree in their yard.
Leah admonished Armando to stop drinking; ensuing quarrel escalated to physical assault—Armando punched and kicked Leah multiple times.
Leah attempted to flee to a neighbor’s house for medicine to treat Armando’s injured foot but was pursued, pushed back, and further assaulted by Armando.
Leah ultimately lost consciousness after Armando banged her head on a wall and laid her head on a stone.
Despite attempts such as pouring water and mouth-to-mouth resuscitation, Leah remained unconscious.

Leah was brought to the hospital but never regained consciousness, dying on August 22, 1996.
Medical examinations by Dr. Jesse Rey T. Cruel (post-exhumation autopsy) and Dr. Canto (neurologist) revealed extensive contusions, abrasions, hematomas, and intracranial hemorrhage indicative of severe blunt force trauma inconsistent with accidental fall.
Injuries included scalp hematoma, signs of strangulation, bruises on various body parts, and signs of violent physical abuse.

Armando denied responsibility, claiming Leah’s injuries resulted from an accidental fall hitting her head on stones after she fled to avoid treating his injured foot.
He indicated hostile relations with his father-in-law due to religious differences and prior interference in his marital affairs.
Armando’s mother and some neighbors testified to a seemingly good marital relationship, denying knowledge of abuse.
Armando surrendered to police weeks after the incident, with voluntary surrender considered as mitigating circumstance.

The Regional Trial Court (RTC), after assessing the testimonies and evidence, found Armando guilty beyond reasonable doubt of parricide.
The RTC sentenced Armando to reclusion perpetua and ordered the payment of P50,000 as civil indemnity to Leah’s children.
The court considered voluntary surrender and a circumstance analogous to passion and obfuscation as mitigating but found no aggravating circumstance.

Whether the appellant inflicted injuries causing Leah Dalag’s death.
Whether the testimonies of Francis and Princess Joy Dalag were credible or fabricated/coached.
Whether the lower court erred in giving credence to the allegations of Marcos Nolido, Jr. (father-in-law) who allegedly had ill motives.