Title
People vs. Argayan y Ognayon
Case
G.R. No. 255750
Decision Date
Jan 30, 2023
Diane Argayan convicted of parricide for killing her 3-year-old daughter, Jeana, through multiple stab and hack wounds; Supreme Court affirmed conviction based on extrajudicial confession, circumstantial evidence, and credible testimony.

Case Summary (G.R. No. 42175)

Key Dates and Procedural Milestones

Crime alleged: on or about May 26, 2014.
Information filed: July 7, 2014 (charging parricide).
Trial court decision (RTC): May 10, 2018 (conviction).
Court of Appeals decision: September 24, 2020 (affirmed).
Supreme Court decision: January 30, 2023 (affirmed with modification as to damages).

Charge and Plea

Charge: Parricide under Article 246, Revised Penal Code — multiple stab wounds at the back and multiple hack wounds to the head allegedly inflicted by the accused upon her child, causing death.
Plea: Accused pleaded not guilty at arraignment. After pre-trial, trial on the merits proceeded.

Factual Narrative as Presented by the Prosecution

On the day of the incident Raven, Diane and Jeana were at Lolo Harry’s house. Raven went to the garden to harvest pechay and later returned to find Jeana crying, with a kitchen knife embedded in her back and clothes bloodied. Jeana allegedly told Raven that her mother stabbed her. Diane was present, removed the knife, cleaned and bathed Jeana, changed and washed her clothes, then put her to sleep and subsequently sent Raven back to the garden, leaving Jeana with Diane. Raven later found Jeana lifeless, with severe head and back wounds. Police responded, processed the scene, found broken bottles beneath a bench, and photographed and sketched the crime scene. Jeana was brought to the hospital and declared dead on arrival. The medico-legal examination by Dr. Leal reported six hack wounds at the back of the head (fatal) and seven stab wounds at the back (one penetrating the left lung), the cause of death being hemorrhagic shock secondary to multiple stab and hack wounds likely caused by a bladed weapon.

Physical and Medical Evidence

Medico-Legal Report No. BSD-050-14, the testimony of Dr. Leal, photographs of the body and crime scene, and the certificate of death established the fact of death and the nature and cause of the injuries (multiple hack wounds to the head and stab wounds to the back consistent with a bladed weapon). Jeana’s birth certificate established Diane as her mother.

Witness Statements and Extrajudicial Admissions

Raven gave a sworn statement identifying the kitchen knife with a black handle as the weapon and stating that Jeana said her mother stabbed her. Social Welfare Officer Girlie testified that during counseling visits Diane admitted to killing Jeana. Diane did not present evidence in her defense and waived her right to present evidence.

Trial Court Findings

The RTC found Diane guilty beyond reasonable doubt of parricide. The RTC credited Raven’s testimony and found it consistent with medico-legal findings. The RTC also evaluated Diane’s mental state and held she was sane before, during and after the killing, considering such factors as her actions after the event (the alleged fabrication of another perpetrator, lack of concern upon seeing Jeana wounded, and alleged admission to Girlie). The RTC imposed the penalty of reclusion perpetua and awarded PHP 75,000 each for civil indemnity, moral damages and exemplary damages.

Court of Appeals Ruling and Reasoning

The Court of Appeals affirmed the RTC. It emphasized the cumulative weight of the testimony and evidence: Jeana’s outcry identifying her mother, Raven’s identification of Diane as the last person seen with Jeana alive, Diane’s conduct (removing the knife, cleaning and bathing Jeana, washing bloodied clothes, leaving Jeana alone with Diane, and later covering the body and cleaning the scene), Raven’s observation of blood on Diane’s feet, the medico-legal report, and Diane’s admission to the social worker. The CA treated Girlie’s account of Diane’s admission not as an extrajudicial confession serving as sole proof but as corroborative, independently relevant evidence that the social worker was told something — the fact of the statement being made was the relevant matter.

Issue on Appeal to the Supreme Court

The sole issue presented to the Supreme Court was whether the Court of Appeals erred in affirming Diane’s conviction for parricide, primarily addressing whether the prosecution proved beyond reasonable doubt that Diane was the killer.

Legal Standard for Parricide and Elements to Be Proven

Article 246, Revised Penal Code: parricide requires proof that (1) a person was killed, (2) the accused was the killer, and (3) the victim is within the specified kinship (here, child of the accused). The Court accepted that elements (1) and (3) were established by the medico-legal findings, death certificate, photographs, and birth certificate. The dispute centered on element (2) — whether Diane was established as the killer.

Admissibility and Effect of Extrajudicial Confession

The Court reviewed constitutional safeguards under Section 12, Article III of the 1987 Constitution and implementing provisions of R.A. No. 7438. Extrajudicial confessions obtained during custodial interrogation must satisfy statutory requirements (written, signed in presence of counsel or other authorized persons upon valid waiver). The Court reiterated jurisprudential distinctions: statements made voluntarily, not in response to custodial interrogation or coercion, and not while the person was under custodial investigation, are not subject to the constitutional requisites for admissibility that apply to custodial confessions. Citing precedents (e.g., People v. Andan), the Court found Diane’s admission to the social worker was voluntary, not the product of custodial interrogation, and not elicited by law enforcement; hence the constitutional safeguards did not render it inadmissible on that ground.

Corpus Delicti Rule and Corroboration Requirement

The Court applied Section 3, Rule 133, Rules of Court: an extrajudicial confession alone is insufficient to convict unless corroborated by evidence of corpus delicti (proof of the commission of the crime). The Court explained corpus delicti requires proof that a certain fact occurred (death) and that a particular person is criminally responsible; the corroborating evidence need only tend to show the commission of the crime and need not independently establish every element beyond reasonable doubt. Here, the medico-legal report, death certificate, autopsy testimony and photographs sufficiently established death and the nature of injuries as corroborative of Diane’s admission.

Circumstantial Evidence and Inference of Guilt

The Court affirmed that conviction may rest on circumstantial evidence when the circumstances proven form an unbroken chain leading to one reasonable conclusion of the accused’s guilt. Applying Section 4, Rule 133, the Court enumerated the critical circumstances: only Diane, Raven and Jeana were at the house; Jeana was left reportedly alone with Diane when Raven first went to the garden; Raven saw Jeana with a knife in her back and Jeana allegedly identified her mother as the attacker; Diane’s conduct in tending to Jeana and then again leaving her alone with Diane; Raven’s observation of blood on Diane’s feet; and Jeana later found lifeless with head and back wounds consistent with a bladed weapon. The trial court’s credibility findings as to Raven were accorded deference; the CA and Supreme Court f

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