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.
parricide
witness testimony
circumstantial evidence

Case Summary (G.R. No. 255750)

Factual Background

On May 26, 2014, three-year-old Jeana Rose Argayan Mangili (the victim) was at the residence of her grandfather in Tiwitiw, Banangan, Municipality of Sablan, Benguet, together with her mother, the accused, and a six-year-old niece, Raven Rhyzl Cha-ong. Raven went to harvest pechay in the garden; Diane followed later, leaving Jeana alone in the house. Raven returned to find Jeana crying with a kitchen knife embedded in her back and her clothes bloodied. Raven reported that Jeana told her that her mother stabbed her. Diane then removed the knife, tended to Jeana, bathed and clothed her, placed her to sleep, and sent Raven back to the garden, leaving Jeana again with Diane. When Raven later checked, Jeana was found lifeless with severe head and back injuries.

Crime Scene and Medical Findings

Police officers who responded observed broken alcoholic bottles and found the victim wrapped in a brown blanket with multiple wounds to the head and back. The victim was declared dead on arrival at the hospital. Medico-Legal Report No. BSD-050-14 prepared by Police Superintendent Jaime Rodrigo Leal recorded six hack wounds at the back of the head that caused intracranial bleeding and seven stab wounds at the back, one of which lacerated the left lung. The stated cause of death was hemorrhagic shock secondary to multiple stab wounds at the back and multiple hacked wounds at the head, likely caused by a bladed weapon.

Investigations and Witness Statements

The police secured the scene, photographed it, and prepared a sketch. Raven gave an account identifying the knife as a kitchen knife with a black handle. Her account was reduced into a sworn statement in the presence of Girlie O. Willie, Social Welfare Officer I of Sablan. Girlie later visited Diane to provide counseling; during their contacts Girlie testified that Diane admitted to killing Jeana.

Trial Court Proceedings

An Information for parricide was filed against Diane. She pleaded not guilty and waived presentation of evidence for her defense. At trial the RTC gave full credence to the testimony of Raven and to the medico-legal findings. The RTC also considered Diane’s statement to the social worker as corroborative evidence. The RTC found Diane guilty beyond reasonable doubt of parricide and imposed the penalty of reclusion perpetua, and ordered payment of civil indemnity, moral damages, and exemplary damages in the amount of PHP 75,000.00 each, with legal interest.

Appellant’s Contentions on Appeal

On appeal Diane argued that the prosecution failed to prove she was the killer because no witness saw her commit the act. She contended it was improbable she could have killed Jeana because she was seen with Raven in the pechay garden immediately before Raven returned. Diane further asserted that her alleged admission to Girlie was inadmissible because it was not in writing.

Prosecution’s Position on Appeal

The People, through the Office of the Solicitor General, maintained that the prosecution proved all elements of parricide. The People relied principally on Raven’s credible testimony identifying Diane as the person responsible, consistency between Raven’s account and the medico-legal report, and Diane’s admission to the social worker. The People also asserted the extrajudicial admission was admissible under Section 26, Rule 130 of the Rules of Court as freely and voluntarily made.

Court of Appeals’ Ruling

The CA affirmed the RTC. It found that while no witness saw the killing, the totality of testimonies established Diane’s responsibility. The CA emphasized Raven’s account that Jeana identified her mother as the assailant, Diane’s conduct after discovering Jeana with a knife embedded in her back, Raven’s identification of Diane as the last person seen with Jeana alive, Diane’s admission to the social worker, and the medico-legal findings. The CA treated Girlie’s testimony concerning Diane’s admission as corroborative and as an independently relevant statement that the fact of its making was material even if the truth of its contents was not determinative as a written confession.

Issue Presented to the Supreme Court

The sole issue submitted was whether the CA erred in affirming Diane’s conviction for the crime of parricide, specifically whether the prosecution established that Diane was the killer.

Supreme Court Ruling

The Supreme Court dismissed the appeal and affirmed the conviction, with modification to expressly impose the penalty of reclusion perpetua and to award PHP 50,000.00 as temperate damages in addition to the damages previously ordered. The awards of PHP 75,000.00 each as civil indemnity, moral damages, and exemplary damages were affirmed. All damages were ordered to earn six percent per annum interest from finality until fully paid.

Legal Reasoning — Elements of Parricide

The Court applied Art. 246, Revised Penal Code and reiterated that to establish parricide the prosecution must prove: (1) a person was killed; (2) the accused was the killer; and (3) the deceased was a specified relative of the accused. The Court found the first and third elements established by the medico-legal report, the death certificate, the birth certificate establishing maternity, the testimony of the medico-legal officer, and uncontroverted photographs and admissions.

Legal Reasoning — Extrajudicial Confession

The Court analyzed Girlie’s testimony that Diane admitted the killing in light of Section 12, Article III, 1987 Constitution and Republic Act No. 7438. The Court explained that the constitutional safeguards protecting persons under custodial investigation apply when a person is under custodial interrogation. The Court found Diane’s admission was not the product of custodial interrogation; it was made voluntarily during counseling visits initiated by Diane, not in response to police interrogation. The Court relied on prior precedents including People v. Andan to hold that an extemporaneous voluntary admission made outside custodial investigation and without coercion is admissible. Accordingly, the Court deemed Girlie’s testimony admissible as evidence of an extrajudicial confession.

Legal Reasoning — Corpus Delicti and Corroboration

The Court reiterated the rule in Section 3, Rule 133 that an extrajudicial confession alone is insufficient for conviction unless corroborated by evidence of corpus delicti. The Court held that the fact of Jeana’s death and the medico-legal findings supplied the required corroboration. The Court explained that the corroborative evidence need not independently prove every element beyond reasonable doubt; it need only tend to show the commission of the crime apart from the confession.

Legal Reasoning — Circumstantial Evidence

The Court affirmed that conviction may rest on circu

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