Case Digest (G.R. No. 217022)
Facts:
The People of the Philippines v. Salve Gonzales y Torno, G.R. No. 217022, June 03, 2019, the Supreme Court Second Division, Lazaro-Javier, J., writing for the Court.Appellant Salve Gonzales y Torno was charged by Information dated September 22, 2009 with parricide for allegedly killing her thirteen‑year‑old son, Ronald (Baron) Gonzales. On arraignment she pleaded not guilty. At pretrial the parties stipulated to appellant’s identity and her relationship to the victim. Trial proceeded with the People presenting four witnesses (Rhey Gonzales, Racel Gonzales, Glena Gonzales, and Dr. Filemon C. Porciuncula, Jr.) and the accused testifying on her own behalf as sole defense witness.
The prosecution evidence consisted chiefly of the eyewitness accounts of Rhey (the eldest sibling, then 15) and Racel (then 11), who described how appellant beat Ronald first with a hanger until it broke, then with the wooden handle of a broom (a “yantok”), striking his head and body; they related that Ronald begged her to stop, vomited and became very weak the next morning, and was later taken by relatives to East Avenue Medical Center where he died. Aunt Glena testified she found Ronald unconscious and pale and assisted in bringing him to medical attention; appellant allegedly refused or delayed taking him to the hospital. Dr. Porciuncula, the medico‑legal officer, testified that the victim had an external swelling and an epidural cavitation with blood clots in the left temporo‑parietal region and that the direct cause of death was an epidural hemorrhage (blood clot) produced by blunt force; he rated the possibility that the injury resulted from a fall as very remote.
Appellant testified she struck Ronald only once on the hands with a hanger as discipline, that he later slipped from the top bunk, and that she assisted in taking him to the clinic and hospital. The trial court (Regional Trial Court, Quezon City, Branch 102) rendered judgment on May 20, 2013 finding appellant guilty beyond reasonable doubt of parricide under Article 246 of the Revised Penal Code and sentenced her to reclusion perpetua, ordering civi...(Pro-only)
Issues:
- Were the elements of parricide proven beyond reasonable doubt?
- Does the mitigating circumstance of lack of intention to commit so grave a wrong apply to appellant?
- Should the trial court’s awards of civil indemnity, moral and exemplary damages, and temperate ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)