GR 101191; (October, 1993) (Digest)
G.R. No. 101191 October 18, 1993
People of the Philippines, plaintiff-appellee, vs. Mario A. Bravo, accused-appellant.
FACTS
In the morning of June 28, 1989, at their house in San Rafael, Bulacan, accused-appellant Mario Bravo told his 11-year-old daughter, Mary Joy, to go to the bedroom and not to mind anything she might later hear. Minutes later, Mary Joy heard a scuffle and her grandmother Elena Sta. Maria’s scream. She rushed out and saw her father in the kitchen with his hands on her grandmother’s head, who was lying prostrate on the floor. Mary Joy ran to call her other grandmother, Natividad Sta. Maria, who had already heard Elena call her name twice. Natividad proceeded to the house and saw Mario choking the bleeding Elena. After loosening Mario’s hold, Natividad, with Mario’s help, carried Elena to bed. Elena stated, “Pinalo ako ni Mario. May tama rin ako sa dibdib.” Elena was brought to the hospital, where she told her daughter, Teofila Bravo (Mario’s wife), “Pinalo ako ng asawa mo. Pinalo ako ni Mario,” a statement also heard by Luisito Sta. Maria. Elena died that same day. The autopsy conducted by Dr. Benito Caballero revealed the cause of death as shock due to cerebral hemorrhage and brain concussion with internal hemorrhage, fractured ribs, ruptured lungs, and pericardium due to multiple traumatic force. Mario claimed the injuries resulted from an accidental fall, a version disputed by Dr. Caballero, who testified the wounds could not have been caused by a simple fall. The Regional Trial Court convicted Mario Bravo of murder.
ISSUE
Whether the trial court erred in convicting accused-appellant Mario Bravo of murder based on the evidence presented.
RULING
The Supreme Court affirmed the conviction but modified the qualification and the civil indemnity. The Court found the prosecution’s evidence, particularly the credible testimonies of Mary Joy and Natividad Sta. Maria, and the dying declarations/res gestae statements of the victim, sufficient to establish Mario Bravo’s guilt beyond reasonable doubt. The Court rejected the defense of accident as absurd in light of the victim’s massive injuries. The Court held that treachery and evident premeditation were not proved, but the crime was qualified as murder due to abuse of superior strength, considering the accused was 43 years old and the victim was 80 years old. The civil indemnity was increased to P50,000.00. The appeal was dismissed.