People vs Mariano (Par.21, Art.

14) Facts: On August 17, 2000 at around 6:00 oclock in the evening, SPO2 Edgardo Hernandez received a call reporting that a woman was seen carrying a rectangular box with a human leg protruding. SPO2 Hernandez together with SPO1 Fidelino responded to the call and a after a car chase, was able to apprehend the said car which was driven by Ruby Mariano, together with her sister, Ruth Mariano, both accused in this case. A cadaver was discovered inside the trunk of the car and was later on identified as Michelle Priol, their helper. During the autopsy, it was found out that the cadaver is already decomposing with an estimate of 3 days, which parts of it were already eaten by animals (i.e. rats), lacerations, and traces of burns which constitutes 72 percent of the whole body. Some of the burns are in the process of healing which was confirmed by a physician saying that it was caused by repeated exposure of the skin to hot materials such as boiling water. Jenny Priol, the sister of the victim, testified that she often visited her sister but was always monitored by the Marianos. In her final visit, since it was the last time she ever saw her sister alive, she saw that the hair of her sister was uneven and said to be done by Ruth. Ruth confessed in her testimony that she doused boiling water on Michelle several times whenever she was angry. This resulted to the deterioration of the latters body which lead to her death as confirmed by the testimony of a physician. On her defense, she said that after she caught the victim stealing from them, her attitude began to change. They would often fight and the only way that she could pacify her is by dousing boiling water on her. She also insisted that the victim died not because she mauled her, but because of sickness. Ruth and Ruby were convicted of murder by the RTC. Ruth was sentenced to death while Ruby was found guilty as an accomplice and was sentenced to reclusion temporal. Issue: WON Ruth and Ruth are criminally liable Held: The Court ruled that the admission made by Ruth of the violence that she inflicted to Michelle by dousing her of boiling water and frequent battery proves her guilt. Her brutality was confirmed by Dr. Aranas who conducted the autopsy. The the wounds inflicted by Ruth were extremely dangerous and would naturally produce fatal consequences. Ruby was acquitted in pursuant to Art. 20 of RVP, wherein it in the said provision includes a sister as an accomplice are exempt from criminal liability by the reason of ones obligation to protect the name and honor of the family. The prosecution also

failed to provide solid evidence against her and also failed to overcome the presumption of innocence. As for Paragraph 21 of the Art.14, her act of putting the lifeless body of Michelle in a box and loading it in the luggage compartment of a car is obviously inconsistent with her profession of innocence. An innocent person would have lost no time in reporting to the police her discovery, right in her own house, of the death of a household member, instead of taking pain in concealing it.