G.R. No. 255750 . January 30, 2023.
People of the Philippines, Plaintiff-Appellee, vs. Diane Argayan y Ognayon, Accused-Appellant.

FACTS

An Information was filed charging Diane Argayan y Ognayon (Diane) with parricide for the killing of her three-year-old daughter, Jeana Rose Argayan Mangili, on May 26, 2014. The prosecution’s version, primarily through the testimony of six-year-old Raven Rhyzl Cha-ong (Raven), Diane’s niece, established that Raven was at their grandfather’s house with Diane and Jeana. Raven went to harvest pechay, and Diane followed later, leaving Jeana alone. When Raven returned to the house, she saw Jeana crying with a knife embedded in her back and bloodied clothes. Jeana told Raven that her mother (Diane) stabbed her. Diane then removed the knife, treated and bathed Jeana, changed her clothes, washed them, and put Jeana to sleep. Diane later sent Raven back to the house after hearing dogs bark, where Raven found Jeana lying face down on the kitchen floor, her head and back oozing blood. Diane covered Jeana’s body with a blanket, cleaned broken glass, and called two men. Police responded and found Jeana’s lifeless body. The medico-legal report indicated Jeana died from hemorrhagic shock due to multiple stab wounds on the back and hack wounds on the head. Raven later identified the knife used. Diane waived her right to present evidence. The Regional Trial Court (RTC) found Diane guilty of parricide, a decision affirmed by the Court of Appeals (CA). Diane appealed, contending the prosecution failed to prove she was the perpetrator, as no witness saw the actual killing, and her alleged admission was inadmissible.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of Diane Argayan y Ognayon for the crime of parricide.

RULING

The Supreme Court found no merit in the appeal and affirmed the conviction. The elements of parricide were established: (1) Jeana was killed; (2) Diane was the killer; and (3) Jeana was Diane’s child. The Court held that while no witness saw the actual killing, circumstantial evidence sufficiently pointed to Diane as the perpetrator. This included: Jeana’s dying declaration to Raven identifying Diane as the one who stabbed her; Diane’s failure to bring Jeana to the hospital immediately after seeing her injured; Diane’s actions of cleaning the scene and changing Jeana’s clothes; and the medico-legal findings consistent with the use of a bladed weapon. The Court also ruled that the testimony of Social Welfare Officer Girlie Willie regarding Diane’s admission of guilt, while not an admissible extrajudicial confession due to lack of writing, was admissible as an independently relevant statement to corroborate other evidence. The totality of evidence proved Diane’s guilt beyond reasonable doubt. The penalty of reclusion perpetua and awards of civil indemnity, moral damages, and exemplary damages were sustained.