FACTS:

The case involves the murder of Michelle Priol, a domestic helper employed by sisters Ruth Mariano and Ruby Mariano. Michelle left her home province to work in Manila due to poverty. Jenny Priol, Michelle's sister, noticed that Michelle had been given an ugly haircut by Ruby. Jenny confronted Ruby, but was met with anger. Afterwards, Ruth and Ruby brought Michelle to Jenny to complain about a broken rice cooker and blamed Michelle. Jenny never saw Michelle again after that incident.

On August 17, 1997, the police received an anonymous call reporting a woman carrying a box with a human leg protruding in Bambang, Pasig City. The caller identified the car with plate number UPR-561. SPO2 Hernandez and SPO1 Fidelino found the car with the reported plate number being driven by Ruth and Ruby Mariano. The police officers followed the car and eventually overtook it. SPO2 Hernandez conducted a visual search of the luggage compartment and found a decomposing body inside a box, later identified as Michelle Priol. The body had multiple traumatic wounds and scalding burns.

During the trial, Ruth Mariano admitted to the abuse inflicted on Michelle. She claimed that Michelle changed after they caught her stealing, and Ruth confessed to dousing Michelle with boiling water, pulling her hair, and banging her head. They had fought multiple times in July 1997 alone. Ruth attempted to treat Michelle's injuries, but she eventually died. Ruth found Michelle's lifeless body in bed and placed it in a box to prevent their mother from seeing it. They were apprehended by the police that evening.

Ruth Mariano was convicted of murder and sentenced to death, while Ruby Mariano was found guilty as an accomplice and sentenced to reclusion temporal. The trial court deemed Ruth's actions as cruelty of the highest order and held Ruby liable for her knowledge of the death and failure to prevent Ruth's acts. The Supreme Court reviewed the case on automatic review but found no compelling reason to overturn the trial court's decision.

The accused-appellant (Ruth Mariano) admitted to engaging in a physical fight with Michelle and splashing her with boiling water when she fought back. The first incident of splashing hot water occurred in July 1997. The accused-appellant also pulled Michelle's hair and banged her head. The autopsy report confirmed that the cause of Michelle's death was multiple traumatic wounds and scalding burns covering 72% of her body surface, which were the same injuries admitted by the accused-appellant.

ISSUES:

1. Whether the death of the victim was the direct, natural and logical consequence of the injuries inflicted by accused-appellant.

2. Whether accused-appellant's acts of pouring boiling water on the victim were accidental.

3. Whether accused-appellant was aware of the effects or danger of pouring boiling water on a human being.

4. Whether accused-appellant's treatment of the victim's wounds and burns with antibiotics and herbal medicine is credible.

5. Whether accused-appellant's act of concealing the victim's body is inconsistent with her profession of innocence.

6. Whether there is solid evidence linking accused-appellant Ruby Mariano to the killing.

7. Whether Ruby Mariano can be held criminally liable for the murder of the victim.

8. Whether Ruby Mariano can be convicted as an accessory after the fact.

9. Whether the qualifying circumstance of cruelty and the generic aggravating circumstance of abuse of superior strength are present in the commission of the crime.

10. Whether the aggravating circumstance of evident premeditation is properly appreciated.

11. Whether or not the imposition of the death penalty in this case is in accordance with the law.

12. Whether or not the records of this case should be forwarded to the Office of the President for the possible exercise of his pardoning power.

RULING:

1. The death of the victim was a direct, natural, and logical consequence of the injuries inflicted by accused-appellant. Accused-appellant's acts of pouring boiling water on the victim caused first and second degree scalding burns covering 72% of the victim's body surface, contributing to her death.

2. Accused-appellant's claim of accidental pouring of boiling water is not credible. The number, nature, and extent of the wounds suffered by the victim show deliberate infliction.

3. Accused-appellant's assertion of unawareness of the effects or danger of pouring boiling water on a human being is not believable. Accused-appellant, being an adult, should have been aware of the lethal effects of such act.

4. Accused-appellant's claim of treating the victim's wounds and burns with antibiotics and herbal medicine is contradicted by the findings of the examining physician who observed no evidence of medical intervention.

5. Accused-appellant's act of concealing the victim's body is inconsistent with her profession of innocence. An innocent person would have reported the death to the police instead of attempting to hide it.

6. There is no solid evidence linking accused-appellant Ruby Mariano to the killing.

7. Ruby Mariano cannot be held criminally liable for the murder of the victim. The evidence presented by the prosecution is insufficient to establish that Ruby had knowledge of the crime or that she had any participation in it. While the circumstances surrounding the case strongly indicate that Ruby had knowledge of what her sister did to the victim, they are not enough to support a finding that she should be held accountable. Ruby's nominal role and lack of positive act or cooperation with her sister's actions do not establish her as a principal or accomplice in the crime. The presumption of innocence in Ruby's favor has not been overcome by proof beyond reasonable doubt.

8. Ruby Mariano cannot be convicted as an accessory after the fact. The act of driving the car where the victim's corpse was hidden, resisting the police's request to stop the car and open the trunk, lying to the police about the contents of the trunk, and refusing to open the box in the trunk do not sufficiently indicate knowledge of the crime and assistance in concealing the evidence. These acts may suggest that Ruby was aware of the crime, but they do not establish her as an accessory after the fact.

9. The Supreme Court found that the qualifying circumstance of cruelty and the generic aggravating circumstance of abuse of superior strength are present. The accused deliberately augmented the wrong by causing another wrong not necessary for the commission of the crime and inhumanly increased the victim's sufferings. Additionally, there was gross physical disparity between the accused and the victim, and the accused took advantage of her superior strength.

10. However, the Supreme Court ruled that the trial court erred in appreciating evident premeditation as an aggravating circumstance. The evidence presented did not establish the elements of evident premeditation, such as the time when the offender determined to commit the crime, an act indicating the culprit's determination, and a sufficient interval of time between determination and execution of the crime to reflect upon the consequences.

11. The Supreme Court affirms the imposition of the death penalty in this case as it is in accordance with Republic Act No. 7659, which amended Article 83 of The Revised Penal Code.

12. The records of this case shall be forwarded to the Office of the President for the possible exercise of his pardoning power.

PRINCIPLES:

• A person is to be held accountable for the natural consequences of their own acts, even if other causes cooperated in producing the fatal result. (Causa causae est causa causati)

• The physical evidence can outweigh unsupported assertions of accidents or unawareness.

• The character and number of injuries suffered by a victim can attest to the deliberate infliction of wounds.

• Credibility can be affected by inconsistencies and attempts to lessen the severity of a crime.

• The lack of solid evidence linking a person to a crime may result in their acquittal.

• The Revised Penal Code exempts accessories from criminal liability when they are related to the principal offender as spouses, ascendants, descendants, legitimate, natural and adopted brothers and sisters, or relatives by affinity within the same degrees. This exemption is based on ties of blood and the preservation of one's name.

• To be convicted as an accessory after the fact, there must be evidence of knowledge of the crime and assistance in hiding or protecting the offender or the evidence of the crime. Mere presence or knowledge of the crime is not enough to establish criminal liability as an accessory after the fact.

• The test in appreciating cruelty as a qualifying circumstance is whether the accused deliberately augmented the wrong by causing another wrong not necessary for its commission, or inhumanly increased the victim's sufferings or outrage, or scoffed at his person or corpse.

• Abuse of superior strength is a generic aggravating circumstance that depends upon the age, size, and strength of the parties involved. To take advantage of superior strength is to purposely use excessive force out of proportion to the means of defense available to the person attacked.

• Abuse of superior strength is capable of being proved and taken into consideration in imposing the sentence, even if it was not alleged in the information. It forms part of the proof of the actual commission of the offense and does not violate the constitutional right of the accused to be informed of the nature and cause of the accusation against him.

• Evident premeditation requires the establishment of external facts which are evident and indicate deliberate planning. Mere presumptions and inferences, no matter how logical or probable, are not enough to sustain a finding of this aggravating circumstance.

• The death penalty is a valid penalty for certain heinous crimes in accordance with the law.

• The Office of the President has the power to exercise pardoning power.