Case Summary (G.R. No. 50884)
Prosecution Evidence
- Dr. Juan L. Dyquiangco, Jr. (Rural Health Officer)
– Performed post-mortem on exhumed corpse (11 December 1974).
– Documented abrasions, contusions and signs of strangulation.
– Noted 7–8 month pregnancy; cause of death: cardiac arrest secondary to strangulation. - Pedro Salufrania (13-year-old son)
– Competence examined under Rule 130 § 19(b), found capable of truthful testimony.
– Eyewitness to evening quarrel, boxing of wife’s abdomen, strangulation, and instantaneous death.
– Testified to threat by father, refusal to live with him, and delay in reporting due to fear. - Narciso Abuyo (maternal uncle)
– Corroborated marriage, pregnancy, and children’s account of violence leading to police investigation.
Defense Evidence
- Geronimo Villan (neighbor)
– Described native “bantil” and “ikmo” treatment administered December 4 morning. - Juanito Bragais (healer)
– Called by accused; arrived after death and assisted in moving the corpse. - Angeles Liling Balce (neighbor)
– Arrived at 6 a.m. December 4; saw wife in coma attributing pain to stomach ailment. - Filomeno Salufrania (accused)
– Denied quarrel or violence; asserted victim died of pre-existing stomach ailment despite herbal treatments.
– Described waking, boiling water, summoning healers, and transporting body by hammock.
Competence and Credibility of Witnesses
– The trial court properly examined Pedro’s capacity and found him intelligent, mature enough to understand an oath and resistant to coercion. Minor inconsistencies (dates, times, phrasing) were attributable to misapprehension of questions and did not affect the core narrative.
– Single credible eyewitness testimony, even if uncorroborated, may sustain conviction.
– Dr. Dyquiangco’s prior experience with ten post-mortems and presumption of official regularity established his competence as expert.
Medical Examination and Expert Testimony
– The autopsy, though on an exhumed body, was competently performed; findings of multiple abrasions and protruding tongue supported strangulation theory.
– No material conflict between medical findings and Pedro’s observations.
Trial Court’s Assessment
– Prosecution witnesses presented coherent, consistent evidence of deliberate violence culminating in parricide.
– Defense witnesses were found to have rehearsed testimony and to exhibit “phenomenal recollection” without corroboration; their version deemed fabricated or unreliable.
– A cloth covering the victim’s face suggested consciousness of guilt on appellant’s part.
Issues on Appeal
I. Competence and credibility of Pedro Salufrania
II. Sufficiency of evidence to establish complex crime of parricide with intentional abortion
III. Credibility assessment of defense evidence
Supreme Court’s Findings
– Trial court did not err in admitting or crediting Pedro’s testimony; minor discrepancies were immaterial.
– Dr. Dyquiangco’s expert opinions were properly received and consistent with eyewitness account.
– Defense version lacked credibility and failed to rebut overwhelming proof of deliberate violence.
– Although respondent
Case Syllabus (G.R. No. 50884)
Facts of the Case
- On or about December 3, 1974, in Tigbinan, Labo, Camarines Norte, Filomeno Salufrania boxed and strangled his lawfully wedded wife, Marciana Abuyo-Salufrania, causing her instantaneous death.
- At the time of her death, Marciana was eight months pregnant; the foetus likewise perished in utero.
- Their 13-year-old son, Pedro Salufrania, and his brother Alex were the only eyewitnesses to the fatal attack.
- After the killing, the accused fetched a hammock, returned the next morning, carried the corpse first to his sister’s house in Tigbinan, then to Gabon, Talisay, for burial.
- Pedro and Alex refused to live with their father, alleging that he threatened to kill them if they revealed the true cause of their mother’s death.
Charge and Information
- Information filed May 7, 1976 before the Court of First Instance of Camarines Norte, Branch I.
- Accused charged with the complex crime of parricide with intentional abortion under Articles 246 and 256(1) of the Revised Penal Code.
- Accused pleaded not guilty upon arraignment.
Trial and Lower Court Ruling
- Trial commenced with presentation of prosecution and defense evidence.
- On August 9, 1978, the trial court found the accused guilty beyond reasonable doubt of parricide with intentional abortion.
- Sentence imposed: death penalty; indemnify heirs of Marciana in the sum of ₱12,000; costs; recommended ₱500 counsel fee to Atty. Marciano C. Dating, Jr.
- As death penalty was imposed, case automatically reviewed by the Supreme Court.
Prosecution Evidence
- Dr. Juan L. Dyquiangco Jr. (Rural Health Officer):
- Exhumed the corpse on December 11, 1974 and performed post-mortem from 12:30 to 2:00 p.m.
- Recorded injuries: multiple abrasions and contusions on left leg and cubital fossa, pinhead-sized wounds on right cheek, swollen right eyelid, protruding tongue indicative of strangulation.
- Noted pregnancy of about 7–8 months.
- Issued written post-mortem report (Exhibit A) and death certificate (Exhibit B), amending cause of death to cardiac arrest post-autopsy.
- Pedro Salufrania (eyewitness aged 13):
- Competency examined and court-found intelligent and free from coercion.
- Testified to quarrel at about 6:00 p.m. on December 3, followed by boxing of his mother’s stomach and strangulation