Case Digest (G.R. No. 255496) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Irma Maglinas y Quindong (G.R. No. 255496, August 10, 2022), the accused-appellant, Irma Maglinas y Quindong, was charged on September 9, 2015 before the Regional Trial Court (RTC), Branch 43, Virac, Catanduanes, with the murder of Krishna Dizon, a one-year-and-four-month-old child. The Information alleged that on May 15, 2015 at around 2:30 PM in Barangay District 3, San Miguel, Catanduanes, Irma, “taking advantage of superior strength,” inflicted injuries on the infant and subsequently drowned her in the Bator River. During trial, the prosecution presented witnesses who recounted hearing slapping sounds and discovering the child’s body face down in the river; the medico-legal officer, Dr. Elva Joson, issued a death certificate citing “Drowning, Freshwater, Accidental” and noted only minor abrasions and blisters. The defense maintained that Krishna was left sleeping at home while Irma briefly went to buy food at a nearby store, and upon returning Case Digest (G.R. No. 255496) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- Irma Maglinas y Quindong (accused-appellant) was charged by Information dated September 9, 2015 with Murder under Article 248 of the Revised Penal Code for allegedly inflicting injuries on and then drowning one-year-and-four-month-old Krishna Dizon on May 15, 2015 in Barangay District 3, San Miguel, Catanduanes.
- Accused-appellant pleaded not guilty at arraignment and trial followed.
- Prosecution Version
- At about 9:30 a.m., witness Eufresina Teves heard a baby crying and sounds like whipping/slapping from the appellant’s house but did not actually see the act.
- At around 3:00 p.m., Krishna was found face-down and floating in a nearby river by accused’s grandson (“Eboy”) and others; her body was retrieved and turned over to appellant, who brought it to the Rural Health Unit (RHU).
- Witnesses observed wounds on Krishna’s eyelids and blood from her mouth; Municipal Health Officer Dr. Elva Joson issued a death certificate labeling the cause as “Drowning, Freshwater, Accidental” and noted minor external injuries (two blisters on right hand, small abrasion at right eye corner) in post-mortem exam, recommending full autopsy.
- Defense Version
- Appellant, a manicurist, was caring for Krishna (left in her custody by mother) on May 15, 2015; she fed and laid the child down to sleep around 1:30 p.m.
- At about 2:00 p.m., she briefly left to buy dinner provisions at a nearby store; returning at roughly 2:14 p.m., she found Krishna missing, and then learned from Eboy that the child’s body was in the river; she attempted resuscitation, changed the child’s clothes, and brought her to the RHU.
- Lower Courts’ Decisions
- RTC (June 6, 2018) convicted appellant of Murder, sentenced her to reclusion perpetua, and awarded civil, moral, exemplary, and temperate damages.
- CA (September 8, 2020) affirmed with modification, adding six-percent per annum interest on damages from finality of decision.
Issues:
- Appellant’s Assignments of Error
- Whether the circumstantial evidence was insufficient to convict her of murder.
- Whether the prosecution failed to prove her guilt beyond reasonable doubt despite her corroborated testimony.
- Prosecution’s Position
- The elements of murder—death, killing by accused, attendant circumstance of treachery, and non-infanticide—were established by the evidence.
- Direct evidence is not indispensable; circumstantial evidence suffices when it produces moral certainty.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)