People v. Rasalan
REITERATIONFacts
The Antecedents: The information charged Severa Jaca and Proceso Rasalan with willfully, unlawfully, and feloniously killing the child born to Severa Jaca, before it was three days old, for the purpose of concealing Severa Jaca's dishonor. Procedural History: The Court of First Instance of Tayabas acquitted Severa Jaca but convicted Proceso Rasalan of infanticide, sentencing him to life imprisonment, accessories of the law, indemnity of P1,000, and half the costs. Proceso Rasalan appealed the decision. The Petition: The appellant, Proceso Rasalan, assigned as errors the reliance on the testimony of prosecution witnesses, the finding of guilt beyond reasonable doubt, the admission of his alleged confession (Exhibit C), and the imposition of the sentence.
Issue(s)
Whether the trial court erred in giving weight to the testimonies of the prosecution witnesses despite alleged grievances. Whether the extrajudicial confession (Exhibit C) signed by the appellant is admissible in evidence. Whether a person who is not an ascendant of the deceased child can be convicted of murder for the killing of an infant less than three days old.
Ruling
The judgment of the Court of First Instance of Tayabas, convicting Proceso Rasalan of infanticide, is affirmed, with the exception of the indemnity, which is omitted. Proceso Rasalan is sentenced to life imprisonment and the accessories of the law, with costs against him.
Ratio Decidendi
On Issue 1: The Supreme Court held that the testimonies of Aurea Zabella (the midwife) and Agapita Navaja (the appellant's relative) were credible and sufficient to establish that Proceso Rasalan asphyxiated the child. The Court noted that even if the witnesses had grievances against the appellant, such grievances were not sufficient to induce them to falsely accuse a relative of such a heinous crime. Furthermore, the testimony of Tomas Jaca regarding the appellant's admission and the attempt to dispose of the body provided strong corroborative evidence of guilt. The consistency of these accounts outweighed the defense's bare allegations of bias. On Issue 2: The Court ruled that the extrajudicial confession contained in Exhibit C was signed knowingly and voluntarily. The Justice of the Peace, Velez Martinez, testified to the regularity of the procedure and stated that the appellant signed the document without any undue pressure. The Court found no reason to doubt the veracity of the Justice of the Peace. Additionally, the confession was corroborated by the physical evidence, specifically the medical examination conducted by Dr. Potenciano, which confirmed that the exhumed corpse died due to asphyxiation, exactly as described in the confession and witness testimonies. On Issue 3: The Supreme Court clarified the legal classification of the crime under the prevailing Penal Code (PC). According to Article 409, paragraph 3 of the PC, when the killer is not an ascendant of the deceased infant, the act is penalized as murder. The Court cited the precedent in U.S. vs. Aquino and Casipit (34 Phil., 813) to establish that the specific mitigating framework of infanticide does not apply to non-ascendants. Because Rasalan was only a brother-in-law and not an ascendant, his criminal liability was correctly pegged as murder. Consequently, the penalty of life imprisonment was appropriate under the law for the violent death of the newborn.
Main Doctrine
The crime of infanticide, defined as the killing of a child within three days after birth, is established by evidence showing the violent death of the infant and the perpetrator's confession or eyewitness testimony, corroborated by medical examination. The penalty for infanticide, when committed by someone who is not an ascendant, is that for murder.