GR 187683; (February, 2010) (Digest)
G.R. No. 187683, February 11, 2010
PEOPLE OF THE PHILIPPINES, Appellee, vs. VICTORIANO DELA CRUZ y LORENZO, Appellant.
FACTS
The appellant, Victoriano dela Cruz y Lorenzo, was charged with Parricide for the death of his wife, Anna Liza Caparas-dela Cruz, on August 18, 2002, in Malolos, Bulacan. The prosecution presented witness Joel Song, who testified that he saw Victoriano punching and kicking Anna outside their house before dragging her inside by her hair. After hearing shouts, Victoriano and Anna emerged, with Victoriano holding Anna, who was bleeding from the mouth. Joel helped bring Anna to the hospital, where she died. The medico-legal report indicated the cause of death as hemorrhagic shock from a stab wound to the trunk, with other injuries noted. Victoriano, in his defense, claimed he came home drunk, and after an argument where he slapped Anna, she fell on a broken jalousie window, which punctured her back. He asserted he immediately sought help and brought her to the hospital, denying any intent to kill.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of Victoriano dela Cruz y Lorenzo for Parricide based on circumstantial evidence.
RULING
The Supreme Court affirmed the conviction. The Court held that circumstantial evidence was sufficient to establish guilt beyond reasonable doubt. The circumstances proven were: (1) Victoriano was seen physically assaulting Anna immediately before the killing; (2) he dragged her into the house; (3) the medico-legal report confirmed injuries consistent with the assault; (4) the fatal nature and location of the stab wound indicated an intent to kill; (5) only Victoriano and Anna were inside the house at the time; and (6) his act of bringing her to the hospital did not negate guilt but could indicate remorse. The Court found no reason to disturb the trial court’s assessment of witness credibility. The mitigating circumstances of lack of intent to commit so grave a wrong and voluntary intoxication were not appreciated, as the nature of the wound showed intent, and intoxication was not proven to be habitual. The penalty of reclusion perpetua was upheld. The awards of damages were modified: civil indemnity was set at ₱50,000.00, moral damages at ₱50,000.00, and exemplary damages at ₱30,000.00.