Case Summary (G.R. No. 255496)
Antecedents
An Information dated September 9, 2015 charged the appellant with murder for allegedly striking the infant Krishna Dizon and then placing her face down in the Bator River, causing her death on May 15, 2015. The appellant pleaded not guilty, and trial proceeded.
Prosecution’s Evidence
Ten witnesses—including neighbors, relatives, and police officers—testified that:
- Around 9:30 a.m., a neighbor heard a child crying and five loud strikes resembling whipping or slapping.
- At about 3:00 p.m., the victim’s body was found floating face down in the river by the appellant’s grandson.
- Observers noted an abrasion at the victim’s right eye corner and blisters on her hand.
- The Municipal Health Officer issued a death certificate citing accidental freshwater drowning, based on relatives’ statements, and recommended autopsy.
Defense’s Evidence
The appellant and two witnesses testified that:
- On May 15, the appellant cared for the sleeping child, then left briefly (around 2:00 p.m.) to purchase food from a nearby store.
- She returned at 2:14 p.m. to find the child missing.
- No one saw her carry the child to the river.
- Her alibi was corroborated by the storekeeper who sold her supplies at the relevant time.
Trial Court Judgment
On June 6, 2018, the Regional Trial Court of Virac convicted the appellant of murder, reasoning that:
- The appellant’s attempted pacification of Krishna by slapping could have been fatal, rendering the child unconscious.
- She then staged an accidental drowning by placing the body in the river.
The court sentenced her to reclusion perpetua and ordered payment of ₱275,000 in civil, moral, exemplary, and temperate damages.
Court of Appeals Decision
On September 8, 2020, the Court of Appeals affirmed the conviction but modified the damage awards to bear six-percent interest from finality. It found that the elements of murder—death, identity of the accused, treachery, and absence of parricide or infanticide—were established, noting the victim’s vulnerability as treachery.
Issues on Appeal
The appellant contended that:
- The circumstantial evidence was insufficient to prove murder.
- Her corroborated testimony was ignored, and the prosecution failed to prove guilt beyond reasonable doubt.
The Solicitor General urged affirmance, asserting that the combined circumstances pointed unerringly to the appellant.
Legal Framework
Under the 1987 Constitution, the accused enjoys the presumption of innocence and the prosecution must prove guilt beyond reasonable doubt. Article 248, RPC defines murder and requires proof of (a) death, (b) identity of the killer, (c) a qualifying circumstance, and (d) absence of other homicide classifications. Rule 133(4) of the Rules of Court permits conviction on circumstantial evidence only if multiple circumstances, each proven, form an unbroken chain excluding other hypotheses.
Analysis of Circumstantial Evidence
The Supreme Court held that the prosecution relied solely on a single circumstance—the sounds heard by a neighbor—which did not satisfy the requirement for more than one proven circumstance. The neighbor did not witness the appellant striking the child and admitted other explanations were possible.
Medical Findings
The post-mortem report and expert testimony showed only minor abrasions and blisters, with no skull fractures or significant trauma. The medical expert confirmed no injuries consistent with lethal force, undermining the theory of fatal maltreatment before drowning.
Identification of the Perpetrator
No witness observed the appellant carrying the victim to the river. The police initially treated her as a witness, and only later de
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Facts of the Case
- On May 15, 2015, one-year-and-four-month-old Krishna Dizon disappeared from the house of her caretaker, accused-appellant Irma Maglinas y Quindong, in Barangay District 3, San Miguel, Catanduanes.
- Prosecution witness Eufresina Teves heard a child crying and five loud slaps or whips around 9:30 a.m.; she assumed the voice was that of accused-appellant.
- Around 3:00 p.m., accused-appellant’s grandson “Eboy” found Krishna face-down and floating in Bator River, roughly 100 meters from the house. The lifeless body was retrieved by neighbors Emmanuel Tatel and Jomar Boiseng.
- Witness Gemma Bernal observed blood from Krishna’s mouth and wounds on both eyelids; the body was wrapped in a white blanket and taken to the Rural Health Unit, where Dr. Elva Joson issued a death certificate citing “Drowning, Freshwater, Accidental.”
- Post-mortem examination revealed only a small abrasion at the corner of the right eye and two blisters on the right hand; Dr. Joson recommended an autopsy to rule out foul play.
- Accused-appellant testified she left Krishna sleeping at around 2:00 p.m. to buy food from a nearby store (corroborated by storekeeper Arlene Tatel) and returned at 2:14 p.m. to discover the child missing. She claimed to have assisted in retrieving the body and attempted resuscitation.
Procedural History
- September 9, 2015: Information for Murder under Article 248, RPC, filed in the RTC of Virac, Catanduanes, Branch 43.
- June 6, 2018: RTC convicted accused-appellant of Murder, sentenced her to reclusion perpetua, and ordered civil, moral, exemplary, and temperate damages of PHP75,000 each and PHP50,000 respectively.
- September 8, 2020: CA in CA-G.R. CR-HC No. 11476 affirmed the RTC Judgment with modification, directing six-percent interest on the damages awards.
- August 10, 2022: Supreme Court granted accused-appellant’s appeal and set the case for resolution.
Issues on Appeal
- Whether the circumstantial evidence presented by the prosecution suffices to overcome the presumption of innocence.
- Whether the defense of alibi and absence of corroborating medic