FACTS:

During the town fiesta in San Pablo, Laguna, the lifeless body of Nora Magpantay was found in her conjugal home. She was six months pregnant and had blood oozing out of her mouth. Her husband, Manolo Villanueva (also known as "Boy" Villanueva), was suspected of beating her to death after she slapped him in front of his friends.

Manolo was charged with and convicted of parricide with unintentional abortion. He claimed that Nora committed suicide by taking sodium cyanide due to family problems and wanting to follow the footsteps of her sister who had previously taken her life. However, Isidro Magpantay, Nora's father, testified that he witnessed Manolo slap Nora during a heated argument. He left, and the next morning, he was informed by Manolo's parents that Nora had poisoned herself.

To substantiate Isidro's testimony and refute Manolo's alibi, Abigail Bandoy, a 15-year-old witness, testified that she witnessed Manolo mauling Nora for about 15 minutes, striking her in different parts of her body. Dr. Nida Glorioso, the City Medical Officer, examined Nora's cadaver and found contusions on her cheek, abdomen, and other body parts. She also failed to find any evidence of poisoning.

Further examination of Nora's stomach and intestines confirmed no presence of poison. Dr. Glorioso concluded that Nora's cause of death was shock due to cerebral concussion from a severe blow on the head.

Manolo testified that he was planning to attend a concert on the night of the incident. He claimed that Nora tried to stop him, but he left their house anyway. He returned early in the morning to find Nora's lifeless body on the floor, along with an empty bottle of sodium cyanide.

The trial court ruled that Manolo was guilty of parricide with unintentional abortion, based on the consistent testimonies of the prosecution witnesses. A review of the testimonies showed no major inconsistencies or discrepancies that would cast doubt on their reliability. The trial court sentenced Manolo to life imprisonment instead of reclusion perpetua, as no penalty of death could be imposed at that time.

ISSUES:

1. Whether the testimonies of the prosecution witnesses are reliable and credible.

2. Whether the alibi and denial of the accused can prevail over the positive testimony of prosecution witnesses.

3. Whether the testimony of the father of the deceased is biased and cannot be credited.

4. Whether the absence of more contusions on the deceased's body rules out the possibility of a blow being administered.

5. Whether the toxicological examination performed by Dr. Glorioso is limited and her conclusions are based only on her opinion.

6. Whether the testimony of witness Abigail, the rebuttal witness, should be given weight and credibility despite the defense's claim of surprise.

7. Whether the delay in reporting the incident by witness Abigail affects her credibility.

RULING:

1. The testimonies of the prosecution witnesses are reliable and credible as they were consistent, in accord with one another, and given in a straightforward manner. There were no material discrepancies or substantial inconsistencies, and there was no evidence of improper motives on the part of the witnesses. The eyewitness account of one witness also conformed with the autopsy findings, making their testimonies more reliable.

2. The alibi and denial of the accused cannot prevail over the positive testimony of prosecution witnesses. The court has repeatedly ruled that alibi and denial cannot overcome credible and positive identification of the accused as the perpetrator of the crime.

3. The testimony of the father of the deceased is not biased and can be credited. While he may have previously shown dislike and bias against the accused, his testimony was limited to witnessing a heated altercation between his daughter and the accused, which is not incriminatory. Relationship with the victim does not automatically categorize a witness as biased.

4. The absence of more contusions on the deceased's body does not rule out the possibility of a blow being administered. The court has previously held that the absence of external injuries does not negate the infliction of a blow by the offender.

5. The toxicological examination performed by Dr. Glorioso is not limited and her conclusions are based on medical findings. The proposition that her examination was limited and her conclusions based on opinion is unsupported by evidence and lacks credibility. Her qualifications as a medical professional are recognized.

6. The Court finds that the defense was not caught by surprise by the testimony of witness Abigail. The defense extensively cross-examined her, which shows that they were aware of her testimony. Therefore, her testimony should be considered and evaluated in determining the guilt or innocence of the accused.

7. The delay in reporting the incident by witness Abigail does not affect her credibility. It has been held that if the delay is sufficiently explained, it does not impair the credibility of the witness or the probative value of the testimony. Fear of reprisal or reluctance to get involved in a criminal case is a valid excuse for the momentary silence of prosecution witnesses.

PRINCIPLES:

• The testimony of a minor of sound mind is likely to be more correct and truthful than that of an older person, once established that the former has fully understood the character and nature of an oath.

• Relationship of a prosecution witness to the victim does not necessarily make him biased and interested in testifying against the accused.

• The absence of external injuries does not preclude the possibility of a blow being inflicted by the offender.

• The court gives deference to the qualifications and expertise of medical professionals in forming conclusions based on medical findings.

• Delay in reporting a crime does not necessarily impair the credibility of a witness or the probative value of their testimony, if sufficiently explained.

• Fear of reprisal or reluctance to get involved in a criminal case is a valid excuse for the momentary silence of prosecution witnesses.