Title
People vs. Dalag
Case
G.R. No. 129895
Decision Date
Apr 30, 2003
A PNP officer, Armando Dalag, was convicted of parricide for fatally assaulting his wife, Leah, after years of domestic violence, despite claims of accidental injury.

Case Summary (G.R. No. 129895)

Facts Leading to the Case

Armando and Leah Dalag were married with three children, residing in Barangay Handumanan, Bacolod City. Their marriage was turbulent and characterized by recurrent violent quarrels and physical abuse inflicted by Armando upon Leah. Neighbors and family testified that Leah often bore contusions and bruises as a result of these altercations. An incident wherein Leah’s father confronted Armando over the abuse further illustrated the volatile family dynamics.

On the evening of August 15, 1996, while the children were watching television, Armando, reportedly intoxicated, physically assaulted Leah in the yard. The children witnessed Armando pushing, kicking, and striking Leah multiple times, including banging her head against a wall, causing her to fall unconscious. Leah fled to a neighbor’s house but was forced back by Armando, who further maltreated her. Despite attempts at resuscitation by Armando and the children, Leah remained unconscious and was later taken to a hospital, remaining comatose until her death on August 22, 1996.

Circumstances Surrounding Surrender and Apprehension

After Leah's death, Armando absconded from his police duty without permission but surrendered on August 28, 1996, pursuant to the order of the station commander.

Medical Evidence and Expert Testimony

A medico-legal autopsy conducted on Leah’s exhumed body revealed extensive abuses including multiple abrasions, contusions, scalp hematomas, and intracranial hemorrhage caused by blunt head trauma. Dr. Jesse Rey T. Cruel and Dr. Canto, a neurological surgeon, opined that injuries were consistent with severe physical violence rather than accidental causes.

Dr. Canto specifically noted finger marks indicative of strangulation, basal skull fractures suggested by bilateral hematomas behind the ears, and other bruises inconsistent with mere falling. He rejected the claim that Leah’s injuries resulted from an accidental fall, explaining that the internal brain injury and other trauma more logically arose from deliberate assault.

Defense of the Appellant

Armando denied intentionally harming Leah. He asserted that Leah’s injuries were the result of an accidental fall after she stumbled on cut bamboo and hit her head on stones. He explained that his stepping on a nail caused his injured foot, leading Leah to purportedly go look for medicine but instead remain at a neighbor’s house, which prompted her flight and subsequent fall. He also challenged the credibility of his children’s testimonies, alleging they were coached to inculpate him.

Witnesses for the defense, including Armando’s mother and a neighbor, testified about the seemingly peaceful marital relationship on that particular evening and did not witness any quarrel or assault.

Trial Court Findings

The RTC found Armando guilty beyond reasonable doubt of parricide for killing his wife. The court gave full credence to the testimonies of the children, Francis and Princess Joy, describing them as candid and believable witnesses who narrated the assault in detail without exaggeration or motive to lie. Their accounts, supported by forensic medical findings, convincingly established Armando’s responsibility for Leah’s death.

The trial court acknowledged mitigating circumstances: voluntary surrender and conduct analogous to passion and obfuscation, then imposed the penalty of reclusion perpetua and ordered civil indemnity of P50,000 to be paid to the victim’s children.

Appellant’s Appeal and Legal Issues

The appellant challenged the trial court’s decision on three grounds:

  1. The court erred in concluding that the injuries inflicted by him caused Leah’s death.
  2. The testimonies of his children were fabricated and coached.
  3. The trial court wrongly credited hostile allegations from the victim’s father, Marcos Nolido, who purportedly bore animus against the appellant.

Supreme Court’s Ruling on Credibility and Evidence

The Supreme Court underscored the trial court’s superior position in assessing witness credibility given its direct observation of witnesses’ demeanor. It found no compelling reason to overturn the RTC’s findings, affirming the reliability of the children’s straightforward and consistent testimonies, which established:

  • Armando’s violent assaults on Leah.
  • Repeated beatings culminating in her falling unconscious.
  • The severity of the injuries leading to death.

The Court also rejected Armando’s theory of accidental injury as medically and factually unsound, emphasizing expert testimony that injuries could not have resulted from a mere fall. Instead, the physical and forensic evidence proved deliberate brutality.

Legal Analysis of Parricide under Article 246, RPC

Parricide is committed when a person kills his spouse or any legitimate ascendant or descendant. Necessary elements include:

  1. Proof that a person was killed.
  2. The accused caused the death.
  3. The victim is related to the accused as spouse, parent, child, or other ascendant/descendant.

All elements were established beyond reasonable doubt. The marriage certificate confirmed the spousal relationship. The injuries and witness accounts proved the fatal assault by Armando.

Penalt

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