Case Digest (G.R. No. 135981)
Facts:
People of the Philippines v. Marivic Genosa, G.R. No. 135981, September 29, 2000, the Supreme Court En Banc, Panganiban, J., writing for the Court. The resolution concerns an Urgent Omnibus Motion filed by Appellant Marivic Genosa y Isidro in the automatic review of the Regional Trial Court (RTC) of Ormoc City, Branch 35, September 25, 1998 Judgment finding her guilty of parricide (Article 246, Revised Penal Code as restored by Sec. 5, RA No. 7659) with treachery and sentencing her to death.The Information (dated November 14, 1996) charged Genosa with killing her husband, Ben M. Genosa, on or about November 15, 1995 in Isabel, Leyte, alleging wounds to the head and other injuries that caused death. After arraignment and trial, the RTC convicted and imposed the death penalty and awarded indemnity and moral damages to the heirs of the deceased. The court of first instance concluded the cause of death was a depressed fracture of the occipital bone resulting in severe intracranial hemorrhage, apparently caused by blows with a metal pipe.
Before filing her appeal brief, appellant submitted an Urgent Omnibus Motion requesting (1) exhumation and re-examination of the victim to determine exact cause of death; (2) psychological/psychiatric examinations of appellant to establish her state of mind and to adduce expert evidence of the so‑called "battered woman syndrome" as a basis for self-defense or mitigating circumstances; and (3) admission of the experts' reports into the record for this Court's automatic review or, alternatively, a partial reopening of the trial in a Metro Manila court to admit such testimony. The solicitor general filed a Comment opposing relief on due‑process grounds. The motion invoked evidence in the trial record indicating prior domestic violence (medical consultations and family testimony), which the RTC had discounted because it found no immediate violence preceding the killing.
The case arrived at the Supreme Court by automatic review of...(Pro-only)
Issues:
- Should the victim's body be exhumed and reexamined to determine the exact cause of death?
- Should appellant be examined by qualified psychologists/psychiatrists so that expert evidence on her state of mind (including the battered woman syndrome)...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)