Case Summary (G.R. No. 173256)
Petitioner and Respondent
Petitioner in the Supreme Court appeal stage: Accused-appellant (Irma) appealed from the Court of Appeals decision affirming her conviction. Respondent in the Supreme Court: People of the Philippines represented by the Office of the Solicitor General.
Key Dates
Incident: May 15, 2015 (death of Krishna).
Information filed: September 9, 2015.
RTC judgment convicting appellant: June 6, 2018.
Court of Appeals decision: September 8, 2020 (affirmed with modification).
Supreme Court decision: August 10, 2022.
Applicable Law and Legal Standard
Offense charged: Murder under Article 248 of the Revised Penal Code (qualifying circumstance invoked: treachery and taking advantage of superior strength). Elements of murder: (a) death of a person; (b) accused caused the death; (c) presence of a qualifying circumstance in Art. 248; (d) killing is neither parricide nor infanticide. Rules on circumstantial evidence: Rule 133, Section 4 of the Rules of Court (circumstantial evidence sufficient for conviction only when there are more than one circumstance, the facts are proven, and combined circumstances produce conviction beyond reasonable doubt). Constitutional baseline: presumption of innocence under the 1987 Constitution; prosecution must prove guilt beyond reasonable doubt.
Procedural Posture
Appellant was arraigned and pleaded not guilty. Trial produced testimony from multiple prosecution and defense witnesses, medical reports, and investigative testimony. RTC found appellant guilty and sentenced her to reclusion perpetua and awarded damages. CA affirmed with modification (interest on monetary awards). Supreme Court reviewed the appeal and ultimately granted it.
Prosecution’s Evidence and Narrative
Prosecution witnesses recounted (a) an early-morning incident in which a neighbor, Eufresina, heard a crying child and sounds she described as whipping/slapping coming from the appellant’s house; (b) discovery in mid-afternoon by community members of the child’s body face-down and floating in the nearby river about 100 meters from the house; (c) observations by lay witnesses and relatives of minor injuries (abrasion at corner of right eye, blisters on right hand) and blood near the mouth/nose; and (d) testimony from the Municipal Health Officer who issued a death certificate (stated cause: drowning, freshwater, accidental) and who recommended autopsy to rule out foul play.
Defense’s Version and Alibi
Appellant testified she was caring for the child while the mother worked elsewhere; around 2:00 p.m. she left briefly to buy food and returned at about 2:14 p.m. to find the house open and the child missing. A household member (storekeeper Arlene) corroborated appellant’s being at the store around that time. A relative (Eboy) discovered the child in the river and brought the body to the house; appellant performed resuscitative efforts before they took the child to the Rural Health Unit. Defense emphasized the absence of eyewitnesses to any assault and that the appellant was not seen going to the river carrying the child.
RTC and CA Findings
The RTC convicted, finding that circumstantial indications and witness accounts showed appellant may have used force while pacifying the child (repeated whipping/slapping), rendered the child lifeless, and then placed the body in the river to simulate drowning. The CA affirmed, concluding the elements of murder (including treachery/taking advantage of superior strength given the victim’s tender years) were present but modified monetary awards to accrue interest.
Issues on Appeal to the Supreme Court
Primary assignments of error: (1) insufficiency of circumstantial evidence to sustain conviction; (2) failure to prove guilt beyond reasonable doubt despite appellant’s corroborated testimony and the prosecution’s evidentiary gaps. The Supreme Court framed the key question as whether the prosecution proved beyond reasonable doubt that appellant was the author of the killing and that the killing was attended by qualifying circumstances.
Supreme Court’s Analysis — Presumption of Innocence and Circumstantial Evidence
The Court reiterated the constitutional presumption of innocence and that the prosecution must establish guilt to the degree of moral certainty. It acknowledged that circumstantial evidence can sustain conviction under Rule 133, Sec. 4, but emphasized that circumstantial proof requires more than a single circumstance and must not rely on inferences drawn from other inferences. The Court stressed that the prosecution’s case must stand on its own strength and cannot derive conviction from the weakness of the defense.
Supreme Court’s Analysis — Medical Findings and Physical Evidence
The Court placed significant weight on the post-mortem examination and testimony of Dr. Joson (Municipal Health Officer). The post-mortem documented only an abrasion at the corner of the right eye and small blisters on the right hand; cause of death was recorded as drowning (freshwater, accidental) and the physician expressly indicated no significant external injuries consistent with severe beating or skull/facial fractures. Dr. Joson testified she did not observe markings indicative of deliberate blows to the head and that fractures would ordinarily be expected if the skull had been intentionally struck. The Court found physical evidence (the post-mortem report and photographs) inconsistent with the prosecution’s theory that appellant repeatedly hit the child and caused fatal injuries prior to drowning.
Supreme Court’s Analysis — Inconclusive Proof of Authorship
The Court found the prosecution’s key circumstantial anchor (neighbor’s hearing of cries and sounds of whipping/slapping earlier in the day) insufficient when considered with the other evidence. The testimony did not establish that appellant was the person heard, nor that the sounds were fatal assaults. Investigative testimony also did not exclude the possibility of other pe
...continue readingCase Syllabus (G.R. No. 173256)
Procedural Posture
- Appeal to the Supreme Court from the Court of Appeals’ September 8, 2020 Decision in CA‑G.R. CR‑HC No. 11476, which affirmed with modification the June 6, 2018 Judgment of the Regional Trial Court (RTC), Virac, Catanduanes, Branch 43, finding Irma Maglinas y Quindong (accused‑appellant) guilty beyond reasonable doubt of Murder under Article 248 of the Revised Penal Code.
- Supreme Court decision rendered August 10, 2022 (G.R. No. 255496), reversing the CA and acquitting accused‑appellant for failure of the prosecution to prove guilt beyond reasonable doubt.
- Court ordered the immediate release of accused‑appellant from detention unless lawfully held for other reasons and directed entry of judgment.
- CA’s modification (affirmed by CA) had been limited to awarding interest at 6% per annum on monetary awards from finality; Supreme Court reversed and set aside the conviction and CA decision.
Case Facts / Antecedents
- Victim: Krishna Dizon, one year and four months old at time of death.
- Date/time/place: Incident occurred May 15, 2015; relevant times include Eufresina hearing crying and slapping at around 9:30 a.m., accused leaving to a store at about 2:00 p.m., accused returning at about 2:14 p.m., and discovery of the body at about 3:00 p.m.; location Barangay District 3, Municipality of San Miguel, Catanduanes, Philippines.
- Discoverers: Jiboy Maglinas, Eboy (Ernie Maglinas, Jr.), Emmanuel, Jomar Boiseng found the victim face down and floating in Bator River about 100 meters from accused‑appellant’s house.
- Context: Jenelyn Dizon (mother) had brought Krishna to Catanduanes and left the child in accused‑appellant’s custody on May 13, 2015 to seek work in Legazpi City.
Information / Criminal Charge
- Information dated September 9, 2015: Accused charged with Murder under Article 248, alleged to have, with intent to kill and taking advantage of superior strength, inflicted physical injuries on Krishna and thereafter drowned her in Bator River, causing death, contrary to law.
- During arraignment, accused‑appellant pleaded not guilty and trial followed.
Prosecution’s Case — Witnesses and Key Testimony
- Principal witnesses presented: Jenelyn Dizon; Eufresina Teves; Gemma Bernal; Police Officer I Gelmar Domagtoy; Emmanuel Tatel; John Cesar Ogena; Dr. Elva Joson (Municipal Health Officer); Senior Police Officer IV Juanito Tevar; Loma Olalo; Police Officer II Cathylene Taule.
- Eufresina: While about 1.5 meters away from accused‑appellant’s house at around 9:30 a.m. on May 15, 2015, she heard a crying child (Krishna) and the voice of accused‑appellant shouting “Tigil! Tigil!” followed by a loud sound of someone being whipped/slapped five times and then louder crying; she did not see accused‑appellant actually hitting the child and admitted she assumed the accused might be scolding.
- Discovery at river: Around 3:00 p.m., Eboy found Krishna face down and floating in the river; he returned and told others, after which the body was retrieved; Jomar shouted “Tiya Irma naheling namo,” signaling Krishna had been found; accused‑appellant then went to the river and took the lifeless body from Eboy.
- Gemma: Upon arrival at accused‑appellant’s house, saw Krishna’s body wrapped in a white blanket on a floor mat; noted wounds on both eyelids and blood continuously coming from the mouth; assisted in bringing the child to the Rural Health Unit.
- Dr. Elva Joson: Issued Death Certificate dated May 18, 2015 indicating cause of death as “Drowning, Freshwater, Accidental” based on information relayed by relatives and the nature of community deaths where the physician need not personally see the deceased; in the post‑mortem examination she noted two blisters on the right hand and a small abrasion at the corner of the right eye and recommended autopsy because of suspicious circumstances.
- Investigating officers and other witnesses: Testified regarding recovery of the body, physical observations at scene, and steps taken during investigation; testimonies varied on whether anyone saw accused‑appellant at the river and on whether other persons were considered possible suspects.
Defense’s Case — Witnesses and Key Testimony
- Defense witnesses: Accused‑appellant, Eboy (who assisted in retrieving the body), and Arlene Tatel (storekeeper).
- Accused‑appellant’s account: On May 15, 2015 she was performing manicurist duties, fed Krishna and put her to sleep around 1:30 p.m., left the child sleeping to go to Arlene’s store at about 2:00 p.m. to buy food, and returned at approximately 2:14 p.m. to find Krishna missing and the door open; she searched the premises and informed family; Eboy later found Krishna at the river and brought the body; accused‑appellant claimed she blew air into Krishna’s mouth and observed blood oozing from the nose; she took Krishna to the Rural Health Unit.
- Arlene Tatel: Corroborated that accused‑appellant went to her store at about 2:00 p.m. and bought food, supporting accused‑appellant’s alibi.
- Eboy: Testified he saw Krishna at the river entangled with rocks wearing a pink dress and diaper, retrieved the body, and handed it to accused‑appellant.
RTC Judgment (June 6, 2018)
- RTC found accused‑appellant guilty beyond reasonable doubt of Murder under Article 248.
- Sentence: Reclusion perpetua; ordered to pay civil indemnity Php75,000.00, moral damages Php75,000.00, exemplary damages Php75,000.00, and temperate damages Php50,000.00.
- RTC’s rationale: Circumstances led to the conclusion that accused‑appellant intentionally hurt Krishna while “pacifying” her from incessant cries by whipping/slapping repeatedly, which could have been fatal; in an attempt to hide the act, accused‑appellant allegedly placed Krishna’s body in the river face down supported by rocks to make it appear accidental.
Court of Appeals Decision (September 8, 2020)
- CA affirmed the RTC judgment but modified the monetary awards to earn interest at 6% per annum from the date of finality until fully paid.
- CA held all elements of Murder were present: (1) Krishna died (Death Certificate), (2) accused‑appellant