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    People vs. Espinosa Digest

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    Emir Mendoza
    The Supreme Court affirmed Espinosa's conviction for parricide based on circumstantial evidence. The prosecution presented testimony that Espinosa was alone with the victim, a six-month old child, who was found dead with multiple injuries inconsistent with falling from a cradle. The medical examiner concluded the injuries, including head fractures, were not caused by a single fall and indicated the child suffered multiple impacts. This circumstantial evidence was sufficient to prove Espinosa's guilt beyond a reasonable doubt.

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    People vs. Espinosa Digest

    Uploaded by

    Emir Mendoza
    2K views2 pages
    The Supreme Court affirmed Espinosa's conviction for parricide based on circumstantial evidence. The prosecution presented testimony that Espinosa was alone with the victim, a six-month old child, who was found dead with multiple injuries inconsistent with falling from a cradle. The medical examiner concluded the injuries, including head fractures, were not caused by a single fall and indicated the child suffered multiple impacts. This circumstantial evidence was sufficient to prove Espinosa's guilt beyond a reasonable doubt.

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    The Supreme Court affirmed Espinosa's conviction for parricide based on circumstantial evidence. The prosecution presented testimony that Espinosa was alone with the victim, a six-month old child, who was found dead with multiple injuries inconsistent with falling from a cradle. The medical examiner concluded the injuries, including head fractures, were not caused by a single fall and indicated the child suffered multiple impacts. This circumstantial evidence was sufficient to prove Espinosa's guilt beyond a reasonable doubt.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    2K views2 pages

    People vs. Espinosa Digest

    Uploaded by

    Emir Mendoza
    The Supreme Court affirmed Espinosa's conviction for parricide based on circumstantial evidence. The prosecution presented testimony that Espinosa was alone with the victim, a six-month old child, who was found dead with multiple injuries inconsistent with falling from a cradle. The medical examiner concluded the injuries, including head fractures, were not caused by a single fall and indicated the child suffered multiple impacts. This circumstantial evidence was sufficient to prove Espinosa's guilt beyond a reasonable doubt.

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    © All Rights Reserved
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    of 2

    People vs.

    Espinosa (2017)

    Plaintiff-appellee: PEOPLE OF THE PHILIPPINES

    Accused-appellant: DOMINADOR ESPINOSA Y PANSOY

    Ponente: Del Castillo (First Division)

    Topic: Criminal Law

    SUMMARY: The SC affirmed Espinosa’s conviction for parricide with circumstantial evidence.

    DOCTRINE: Parricide is committed when: (1) a person is killed; (2) the deceased is killed by the accused; (3)
    the deceased is the father, mother, or child, whether legitimate or illegitimate, or a legitimate other ascendant or
    other descendant, or the legitimate spouse of accused.

    It is settled that "[d]irect evidence of the actual killing is not indispensable for convicting an accused when
    circumstantial evidence can sufficiently establish his guilt." Circumstantial evidence can be the basis for
    conviction if there is more than one circumstance, the facts from which the inferences are derived have been
    proven, and the combination thereof produces a conviction beyond reasonable doubt.

    Only moral certainty, and not absolute certainty, is required for a conviction.

    FACTS:

    The prosecution presented the testimony of Edeltrudes Medina (Medina), the mother of the victim (Junel),
    and live-in partner of Espinosa. She narrated that on March 14, 2009, she left Junel, then six months old, under
    Espinosa's care as she went to help in her aunt's catering business. On March 15, 2009, while at her aunt's
    house, she received a phone call from Espinosa informing her that Junel had fallen off the cradle and died.
    Medina immediately went home where she found Espinosa seated before the lifeless body of Junel. Noting that
    Junel's mouth had injuries, his upper lips and chest had cigarette burns and his chest had hematomas, she was
    unconvinced that Junel had really fallen off the cradle.

    The prosecution also presented the testimony of Dr. Felimon C. Porciuncula, Jr. (Dr. Porciuncula) who
    conducted the autopsy on the body of the victim and issued Medico- Legal Report No. A-164-09. Dr. Porciuncula
    testified that Junel had several contusions on the lips, ear, head, lungs and lower back; abrasions on the lips,
    head, chest and lower back; and fractures on two different parts of the head – injuries which were not sustained
    merely from falling off a cradle. He concluded that the cause of death of the victim was the traumatic injuries
    sustained in the head and trunk.

    Espinosa was charged of parricide. RTC convicted him of the crime charged. CA affirmed.

    ISSUES:

     WoN Espinosa is guilty of parricide


    o YES. the circumstances already identified and enumerated by the appellate court bear restating.
    First, Espinosa was the only adult present at the time of the incident. Second, Junel suffered
    several hematomas and cigarette burns on different parts of his body which were inconsistent
    with the alleged accidental falling off the cradle. Third, the medico-legal report revealed that Junel
    had sustained injuries which could not have been caused by mere falling off the cradle.
    o The extent of the injuries sustained by Junel and the impossibility that these had been sustained
    by mere falling off the cradle were sufficiently explained by Dr. Porciuncula:
     Q: Could they have been made on a single time, the injuries, single infliction?
     A: No, sir.
     Q: Why so?
     A: Because the location of the injuries are located on different parts of the body, especially
    on the left and right side[s] of the head including the back portion of the head, the anterior
    portion of the head, sir. All portions of the head were injured, sir.

    NOTES: Appeal DISMISSED. Espinosa GUILTY of parricide.

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