G.R. No. 47795 ; August 24, 1942
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PACIANO CRUZ, defendant-appellant.

FACTS

Appellant Paciano Cruz and the deceased Remedios Eustaquio were married and lived together in San Juan del Monte, Rizal. Their marital peace was occasionally disturbed by appellant’s jealousy against a man named Emong, whom he suspected of having illicit relations with his wife. Remedios was last seen alive on the afternoon of May 2, 1937, when she went to her husband’s poultry farm in barrio Once to bring him his merienda. After her disappearance, appellant told her father, Antonino Eustaquio, and the chief of police that she had run away with another man. On August 11, 1939, acting on information about a woman’s apparition and a filled-in well near appellant’s house, Antonino Eustaquio, accompanied by various officials, caused the well to be excavated. The excavation revealed a human skeleton found upside down, along with a locket bearing the initial “M,” slipper soles, and an iron bolt. The skeleton had two gold crowns and four ivory teeth in the skull. A medico-legal analysis determined the remains were of a female aged 25-30, about 153 cm tall, interred approximately two years prior, and showing signs of violence on the skull, ribs, and scapula, with the cause of death likely being a violent blow from a blunt instrument. Appellant was charged with parricide. He subsequently made a written confession before constabulary agents, detailing how he killed his wife out of jealousy, struck her with an iron bolt, and, with the help of another, buried her in the well. He also identified the articles found with the skeleton as belonging to his wife. Later, he reconstructed the crime on the spot. After trial, he was convicted of parricide and sentenced to reclusion perpetua, with accessory penalties and an indemnity. He appealed the conviction.

ISSUE

1. Whether the unearthed skeleton is positively identified as that of Remedios Eustaquio.
2. Whether the evidence proves beyond reasonable doubt that appellant caused her death.

RULING

The Supreme Court affirmed the judgment of conviction.
1. On the identity of the skeleton: The evidence conclusively establishes that the skeleton is that of Remedios Eustaquio. Dr. Manuel Francisco identified the dental work (two gold crowns and four ivory teeth) as matching exactly what he performed on Remedios. This was corroborated by appellant’s own admission in court and the testimony of the victim’s father. The locket with the initial “M” (for “Miding,” her nickname) and the slipper soles were also identified as hers. The medico-legal findings on age, height, and time of interment corresponded with Remedios’s description and the date of her disappearance. The signs of violence on the bones were consistent with a blow from an instrument like the iron bolt found.
2. On appellant’s guilt: Appellant’s detailed confession, which the Court found to be voluntary and not extracted through torture, is decisive. The confession narrates the history of their relationship, his jealousy, and the specific circumstances of the killing on May 2, 1937 (referred to in the confession text as “May 2, 1940,” a clerical error), including striking her with an iron bolt and burying her with the help of Hilarion. The Court found the confession spontaneous, coherent, and replete with details only the accused could know. The claim of torture was denied by multiple prosecution witnesses, and the Court found no reason to disbelieve them. The confession is strongly corroborated by: (a) the testimony of eyewitness Enrique Quendo, who witnessed the killing and aided in the burial; (b) appellant’s own reenactment of the crime; (c) his refusal to handle the iron bolt during the reenactment, stating he might kill again; and (d) the physical evidence unearthed. The Court rejected the argument that it was unbelievable for appellant to confess after two years, noting that faced with the discovery of the body and overwhelming evidence, confession is a natural recourse. Therefore, the corpus delicti and appellant’s guilt were proven beyond reasonable doubt.