Facts:

The case involves Dominador Espinosa y Pansoy (appellant), who was charged with parricide in the Regional Trial Court (RTC) of San Mateo, Rizal, on August 4, 2009. The charge stemmed from an incident that occurred on March 14, 2009, in the Municipality of Rodriguez, Rizal, where the appellant allegedly pushed the cradle of his six-month-old biological child, Junel Medina y San Jose, against the wall, resulting in traumatic injuries that led to the child's death. The prosecution's case was primarily based on the testimony of Edeltrudes Medina, the mother of the victim and live-in partner of the appellant. She testified that she left Junel under the care of the appellant while she assisted in her aunt's catering business. Upon receiving a call from the appellant on March 15, 2009, she rushed home to find Junel lifeless, with visible injuries including cigarette burns and hematomas. The prosecution also presented Dr. Felimon C. Porciuncula, Jr., who conducted the aut...

Facts:

Background and Charge

• On August 4, 2009, Dominador Espinosa y Pansoy (appellant) was charged with parricide for the death of his six-month-old son, Junel Medina y San Jose. The incident allegedly occurred on March 14, 2009, in Rodriguez, Rizal. The Information stated that appellant intentionally pushed the cradle of Junel against the wall, causing traumatic injuries to the head and trunk, which led to the child's death.

Prosecution's Version

• Testimony of Edeltrudes Medina (Mother of the Victim):
  • On March 14, 2009, Medina left Junel under appellant's care while she went to help her aunt. The next day, appellant called her to inform her that Junel had fallen off the cradle and died. Upon returning home, Medina found Junel lifeless with injuries inconsistent with a fall, including cigarette burns, hematomas, and contusions.
• Testimony of Dr. Felimon C. Porciuncula, Jr. (Medico-Legal Officer):
  • The autopsy revealed multiple injuries, including contusions, abrasions, and fractures on Junel's head and trunk. Dr. Porciuncula concluded that these injuries were not caused by a mere fall from a cradle and were the cause of death.

Defense's Version

• Testimony of Appellant:
  • Appellant claimed he was home sick on the day of the incident. He left Junel and his two-year-old daughter, Althea, sleeping while he fetched water. Upon returning, he found Junel lying face down on the floor with blood on his lips. He insisted that Junel was still alive at that time and had even given him milk. However, Junel later died during the night.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Elements of Parricide:

   • The crime of parricide requires: (1) a person is killed; (2) the deceased is killed by the accused; (3) the deceased is the father, mother, child, or spouse of the accused. All elements were proven in this case.

2. Circumstantial Evidence:

   • Direct evidence is not necessary for conviction if circumstantial evidence sufficiently establishes guilt. The following circumstances pointed to appellant's guilt:
     • Appellant was the only adult present at the time of the incident.
     • Junel suffered injuries inconsistent with a fall, including cigarette burns and hematomas.
     • The medico-legal report confirmed that the injuries could not have been caused by a mere fall.

3. Moral Certainty:

   • Conviction requires moral certainty, not absolute certainty. The Court found that the circumstantial evidence produced moral certainty of appellant's guilt.

4. Penalty and Damages:

   • The penalty for parricide is reclusion perpetua to death. Given the absence of modifying circumstances, reclusion perpetua was imposed. Appellant is not eligible for parole under Republic Act No. 9346.
   • Damages were awarded as follows:
     • Civil indemnity: P75,000.00
     • Moral damages: P75,000.00
     • Exemplary damages: P75,000.00
     • Temperate damages: P50,000.00
   • All monetary awards shall earn 6% interest per annum from the finality of the decision until full payment.