G.R. No. 128089 February 13, 2001
People of the Philippines vs. Dominador Velasco alias “Ador”

FACTS

Accused-appellant Dominador Velasco was charged with the parricide of his wife, Priscilla Velasco. The prosecution’s case was built on circumstantial evidence. On the afternoon of October 27, 1990, a witness saw the accused, armed with a piece of wood, aggressively chasing the victim while shouting, “I will kill you now.” The victim was heard calling for help. Later that day, she was found dead. Initial reports suggested suicide by poisoning, a conclusion made by a rural health doctor who did not perform an autopsy. Doubting this, the victim’s mother requested an exhumation and autopsy by the NBI.
The NBI autopsy revealed the victim suffered multiple traumatic injuries, including abrasions, hematoma, and contusions, consistent with being struck by a hard object like a wooden club. Toxicological tests found no poison in her system. The cause of death was officially determined to be shock secondary to multiple traumatic injuries. The defense presented a different narrative, claiming the accused discovered his wife in an adulterous act that morning, chased her paramour unsuccessfully, and later learned of her death, which he alleged was by suicide.

ISSUE

Whether the circumstantial evidence presented by the prosecution is sufficient to prove beyond reasonable doubt that the accused-appellant killed his wife, thereby committing parricide.

RULING

Yes, the Supreme Court affirmed the conviction. The Court meticulously examined the chain of circumstantial evidence, which, when taken together, leads to a logical and moral certainty of the accused’s guilt. The established circumstances were: (1) the accused was seen chasing the victim with a wooden club while uttering death threats; (2) the victim was heard calling for help; (3) she was found dead shortly thereafter; (4) the autopsy conclusively proved death was caused by multiple traumatic injuries consistent with a club beating, not poisoning; and (5) the accused had a motive, having previously maltreated his wife due to suspicions of infidelity, as evidenced by a prior barangay case. These facts form an unbroken chain consistent only with the hypothesis that the accused killed his wife and inconsistent with any other rational conclusion, such as suicide.
The Court emphasized that a conviction based on circumstantial evidence is valid when the combination of circumstances produces a conviction beyond reasonable doubt. All elements of parricide were proven: the killing of a person, perpetrated by the accused, and the victim being the legitimate spouse, as admitted by the accused himself. With no aggravating or mitigating circumstances, the penalty of reclusion perpetua and an award of P50,000 civil indemnity were correctly imposed by the trial court.