People of the Philippines vs De Vera
GR No. 11316 October 30, 1996
Facts: In the afternoon of September 30, 1990, Irma Aspurias De Vera, the young housewife of the accused, was at home with household helper Francisca Eugenio, their tenant Lorna Anteola, the accused sister Rowena De Vera-Jesuitas and the latter’s husband Arnel Jesuitas. At about 3:00pm, Irma’s husband accused Ronald De Vera arrived. Ronald asked Irma, who was then at the kitchen with Francing and Lorna, to join him in the bedroom upstairs in order to discuss an important matter. Within minutes, Lorna heard a commotion in the couple’s bedroom. She could hear that the two were engaged in a shouting match. Then, there was a complete silence. After awhile, sensing that all is well again, Lorna went upstairs. To her surprise, she saw Ronald, assisted by Arnel carrying a disabled Irma out of the room. The latter was brought to the Quezon City Medical Center where she was pronounced dead on arrival. Looking over at the couple’s bedroom, Lorna and Francing saw that the place was in disarray. In the medico-legal examination conducted on October 4, 1990, by the police, the cause of death was said to be asphyxia by hanging. The National Bureau of Investigation (NBI), at the request of the commission on Human Rights (CHR) undertook its own investigation of the case. Irma’s body was exhausted, and a second autopsy was conducted. This time the cause of death was found to be asphyxia compatible with strangulation. The defense sought to convince that Irma took her own life.
Issue: Whether or not the autopsy report is binding as evidence for the crime charged to the respondent.
Held: Yes. It might be stressed that Dr. Bautista, in making his examination and in identifying the cause of death, did not fail to take into account the wounds which were apparently inflicted after Irma’s death, such as the incise wound on the other right side of the neck and the wound on the wrist of the left side or antero-lateral aspect.
The corpus delicti indications that the victim was strangled to death, exemplified by contuse-abrasions on the victim’s neck and other parts of the body characterized by marked congestions on the superior part of the first portion of the trachea and the thyroid cartilage which was even detected by the NBI medico-legal officer Dr. Bautista at the time he conducted an autopsy on the victim’s body.