GR 140348; (July, 2003) (Digest)
G.R. No. 140348 ; July 18, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. GERRYMEL ESTILLORE Y POSTICO, appellant.
FACTS
In the early morning of April 2, 1997, in Rosario, Cavite, appellant Gerrymel Estillore and his common-law wife, Mary Jane Del Carmen, were heard having a heated argument in their home. Prosecution witness Andres Cadavis, a tricycle driver, heard appellant shouting expletives and sounds of a struggle. Another witness, Alfredo Guinaja Jr., later heard thuds from the couple’s brightly lit house. Guinaja then saw appellant jump out of a window carrying their child, calmly stating their house was on fire and asking for help. Guinaja forced open the door and extinguished flames engulfing a figure, which was later identified as Mary Jane. The victim, with severe burns, was rushed to the hospital where she repeatedly pleaded for help, explicitly stating to appellant’s sister, “Ate tulungan mo ako dahil sinunog ako.” She died later that day from third-degree burns.
The defense presented a different version, claiming the fire was an accident caused by a gas lamp that Mary Jane accidentally knocked over during an argument. Appellant testified he tried to save her by smothering the flames with a blanket before escaping with their child. The Regional Trial Court convicted appellant of murder qualified by treachery and sentenced him to reclusion perpetua. The case was elevated to the Supreme Court on automatic review.
ISSUE
The core issue is whether the prosecution proved beyond reasonable doubt that appellant committed murder, qualified by treachery, or if the death resulted from an accident.
RULING
The Supreme Court affirmed the conviction for murder, finding the prosecution’s evidence sufficient to establish guilt beyond reasonable doubt. The Court upheld the presence of treachery, noting the attack was sudden and deliberate, ensuring the victim had no opportunity to defend herself. The circumstantial evidence formed an unbroken chain leading to the conclusion that appellant was the perpetrator. This evidence included the prior violent argument, appellant’s calm demeanor and immediate flight from the scene without attempting to rescue the burning victim, the physical evidence at the scene, and the victim’s dying declaration implicating him. The Court found the defense of accident unconvincing and inconsistent with the evidence. The penalty of reclusion perpetua was affirmed, and appellant was ordered to pay civil indemnity, moral, and actual damages to the victim’s heirs.