G.R. No. 215750 , August 17, 2016
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CARLITO TAYAO y LAYA, Accused-Appellant

FACTS

The accused-appellant, Carlito Tayao y Laya, was charged with the parricide of his wife, Ma. Theresa Tayao y Fernandez. The Information alleged that on November 22, 2000, in Dasmarifias, Cavite, Carlito, with intent to kill, willfully mauled and strangled his wife using a stretchable plastic hose, causing her death from asphyxia by ligature strangulation.
The prosecution’s version, primarily through the testimony of daughter Clarisse, established that on the morning of November 22, 2000, Clarisse and her sister found their mother lifeless on the floor with a plastic hose tied around her neck and blood oozing from her nose. Their aunt, Rizza, responded and tried to revive Ma. Theresa. Carlito, who was awakened by the commotion, stated, “Wala na ‘yan.” The victim was pronounced dead on arrival at the hospital. The prosecution also presented evidence of the couple’s tumultuous relationship, including fights the night before the incident, Carlito’s alleged physical abuse of his wife and children, and his alleged drug use. The parties stipulated that Dr. Antonio Vertido, an NBI medico-legal officer, would testify that the cause of death was asphyxia by ligature strangulation.
The defense presented Carlito and his daughter, Cate Lynn. Carlito claimed he discovered his wife already dead with the hose around her neck, its other end tied to a decorative block in the bathroom. He asserted he tried to resuscitate her and believed she committed suicide due to jealousy over his ex-girlfriend. Cate Lynn testified that two days prior, she witnessed her mother attempting suicide with a hose. On cross-examination, Carlito admitted he and his wife had a fight the night before, the bathroom door was too low for hanging, and the cause of death was strangulation. Cate Lynn admitted she did not witness the actual incident and that Carlito had banged her head against a wall previously.
The Regional Trial Court (RTC) found Carlito guilty beyond reasonable doubt of parricide, sentencing him to reclusion perpetua and ordering him to pay ₱50,000.00 as civil indemnity. The Court of Appeals (CA) affirmed the conviction but modified the damages, awarding ₱50,000.00 as civil indemnity and ₱50,000.00 as moral damages.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Carlito Tayao y Laya for the crime of parricide.

RULING

The Supreme Court AFFIRMED the conviction with MODIFICATIONS. The Court held that the prosecution successfully proved Carlito’s guilt beyond reasonable doubt through circumstantial evidence. The concurrence of the following circumstances led to an unbroken chain consistent only with his guilt: (1) the medico-legal finding of death by ligature strangulation; (2) the improbability of suicide given the low bathroom door and the presence of contusions on the victim’s forehead; (3) the motive arising from the couple’s violent quarrel the night before the killing; (4) Carlito’s unnatural reaction and lack of effort to help his wife; and (5) his flight and failure to submit a counter-affidavit. The defense of suicide was deemed weak and unsupported by evidence.
The Court modified the penalty and damages. Carlito is sentenced to suffer reclusion perpetua without the benefit of parole. The awards for damages are increased in line with prevailing jurisprudence: ₱100,000.00 as civil indemnity, ₱100,000.00 as moral damages, and ₱100,000.00 as exemplary damages. Furthermore, the Court awarded ₱50,000.00 as temperate damages since the heirs incurred burial expenses though the exact amount was not proven. All monetary awards shall earn interest at 6% per annum from the finality of the decision until fully paid.