GR 116726; (July, 1997) (Digest)
G.R. No. 116726 July 28, 1997
People of the Philippines, plaintiff-appellee, vs. Leonardo P. De la Cruz, accused-appellant.
FACTS
Accused-appellant Leonardo P. de la Cruz was charged with parricide for beating his wife, Violeta Tulud, to death. On the evening of September 12, 1991, after arriving home from a drinking spree, he confronted his wife about rumors of her having a lover. A violent quarrel ensued, during which he boxed and slapped her. Violeta ran out of the house to a nearby field, with Leonardo pursuing her. He overtook her and, according to the testimony of their 8-year-old daughter Annabelle, pushed her head hard against the ground with both hands. Violeta returned to the house, asked for water, and died shortly after. The autopsy revealed a fracture at the base of the skull and other injuries, with the cause of death being internal hemorrhage secondary to the skull fracture. The accused claimed Violeta died from an accidental fall after she stumbled while running away. The trial court convicted him based on Annabelle’s testimony and the medical findings.
ISSUE
Whether the trial court erred in convicting the accused-appellant of parricide, particularly in relying on the credibility of the child witness Annabelle’s testimony.
RULING
The Supreme Court affirmed the conviction. The testimony of the child witness Annabelle was found to be clear, spontaneous, and credible. Her account of her father pushing her mother’s head to the ground was consistent and supported by the medical findings, which contradicted the claim of an accidental fall. The Court held that a child of tender age cannot be expected to understand every question perfectly, and the trial judge’s assessment of her competence to testify is accorded respect. There was no reason for her to fabricate charges against her own father. The guilt of the accused-appellant was established beyond reasonable doubt. The decision sentencing him to reclusion perpetua and ordering him to indemnify the heirs of Violeta Tulud in the amount of P50,000.00 plus costs was affirmed.