GR 95851; (March, 1995) (Digest)
G.R. No. 95851 March 1, 1995
People of the Philippines, plaintiff, vs. Manolo Villanueva alias “Boy” Villanueva, accused.
FACTS
On January 14, 1989, during the town fiesta of San Pablo, Laguna, a heated argument occurred between Manolo Villanueva and his six-month pregnant wife, Nora Magpantay. Isidro Magpantay, Nora’s father, witnessed the accused, who was drunk, slap his daughter in the afternoon. That evening, in front of his friends, Nora slapped Manolo, causing him embarrassment. Later, between 7:30 and 8:00 PM, eyewitness Abigail Bandoy, then 15 years old, saw Manolo maul Nora for about fifteen minutes, striking her several times in the stomach and different parts of her body despite her pleas to stop, until Nora fell unconscious on the cement floor. Manolo then left. The following morning, Nora was found dead. The accused claimed his wife committed suicide by drinking sodium cyanide due to family problems. However, Dr. Nida Glorioso, the City Medical Officer, conducted an autopsy and found contusions on the victim’s body, notably on the left cheek and eye, and a bloody discharge from her mouth. Toxicological examination of the victim’s stomach and intestines at the PC Crime Laboratory yielded negative results for all poisons, including cyanide. Dr. Glorioso concluded the cause of death was shock due to cerebral concussion secondary to a severe blow on the head. The Regional Trial Court convicted Manolo Villanueva of the complex crime of parricide with unintentional abortion and initially sentenced him to life imprisonment.
ISSUE
Whether the accused, Manolo Villanueva, is guilty beyond reasonable doubt of the complex crime of parricide with unintentional abortion.
RULING
Yes. The Supreme Court affirmed the conviction but modified the penalty. The Court found the testimonies of prosecution witnesses Isidro Magpantay and Abigail Bandoy, corroborated by the medical findings of Dr. Glorioso, to be credible, consistent, and given in a straightforward manner. The negative toxicology report conclusively refuted the accused’s claim of suicide by poisoning. The accused’s alibi and denial could not prevail over the positive identification and testimonies of the prosecution witnesses. The complex crime of parricide with unintentional abortion was duly proven. However, the penalty imposed by the trial court was corrected. The Court held that the penalty for parricide under Article 246 of the Revised Penal Code is reclusion perpetua, not life imprisonment, as the two are distinct penalties. The decision was AFFIRMED with MODIFICATION, sentencing the accused to reclusion perpetua and increasing the civil indemnity to P50,000.00 and moral damages to P30,000.00, while the award of actual damages and costs of P3,000.00 remained.