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:
- The court erred in concluding that the injuries inflicted by him caused Leah’s death.
- The testimonies of his children were fabricated and coached.
- 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:
- Proof that a person was killed.
- The accused caused the death.
- 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
...continue readingCase Syllabus (G.R. No. 129895)
Procedural History and Nature of the Case
- This appeal arises from the decision dated January 10, 1997, of the Regional Trial Court (RTC) of Bacolod City, Branch 42, in Criminal Case No. 17838.
- The appellant, PO3 Armando C. Dalag, a member of the Philippine National Police, was found guilty beyond reasonable doubt of parricide for the killing of his wife, Leah Nolido Dalag.
- The RTC sentenced the appellant to reclusion perpetua and ordered him to pay their children the amount of P50,000.00 as civil indemnity.
- The prosecution charged the appellant under Article 246 of the Revised Penal Code (RPC), as amended by RA 7659, with parricide committed with evident premeditation.
Facts and Background
- Armando Dalag was lawfully married to Leah Nolido Dalag; the couple had three children: Francis, Princess Joy, and Ezra John, and resided in Barangay Handumanan, Bacolod City.
- The marital relationship was tumultuous, characterized by violent quarrels, with Leah often sustaining physical injuries including contusions and bruises.
- Leah’s father, Marcos Nolido, had previously intervened due to Armando’s physical abuse, which Armando dismissed stating his intention to sell the house and leave Leah.
- On August 15, 1996, around 8:00 p.m., the appellant, while intoxicated and under the influence of hard liquor, physically assaulted Leah extensively under a datiles tree in their yard, witnessed by their children.
- The children heard their parents quarrelling, saw the appellant push, kick, punch, and bang Leah's head against a wall, causing severe injuries.
- Despite Leah fleeing the scene and attempts to revive her when she lost consciousness, she remained incapacitated and was later brought to the hospital.
- Leah remained unconscious until her death on August 22, 1996.
- The appellant temporarily absconded after Leah’s death but later voluntarily surrendered to the police.
Medical and Forensic Evidence
- Dr. Jesse Rey T. Cruel, medico-legal officer of the Commission on Human Rights, conducted a post-mortem examination revealing multiple abrasions, contusions, scalp hematoma, and intracranial hemorrhage secondary to blunt trauma as the cause of death.
- The injuries were found on various parts of Leah’s body, including the chest, extremities, head, and face, consistent with severe physical abuse.
- Dr. Canto, a neurological surgeon, testified about the nature of Leah’s injuries, highlighting basal skull fractures, bruises resembling fingermarks on the neck consistent with strangulation, and internal brain injuries.
- Dr. Canto disbelieved the appellant’s claim that the injuries resulted from an accidental fall, emphasizing the inconsistency between the extent and nature of injuries and the alleged accident.
- Both medical experts confirmed the injuries as causing Leah’s death and resulted from violent physical assault rather than mere accidental trauma.
Testimonies of Witnesses
- Principal witnesses were the appellant’s children, Francis and Princ