327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Can a mother be convicted of parricide for the brutal
killing of her 13-year-old son, based on the testimony of her other children?
Case Title: People of the Philippines v. Salve
Gonzales y Torno
G.R. No. 217022 | June 3, 2019
Facts of the Case:
Salve Gonzales y Torno was charged with parricide for the
death of her 13-year-old son, Ronald Gonzales. The incident occurred on
September 16, 2009, in Quezon City, when Salve returned home to find out that
Ronald had sold a bronze electrical wire from their house. She reacted by
severely beating Ronald with a hanger and then a broomstick (wooden handle),
hitting his head and body, while her other children, Rhey and Racel Gonzales,
witnessed the assault.
The next morning, Ronald showed signs of severe injury,
including vomiting and weakness, but Salve did not bring him to the hospital,
claiming he was pretending. Ronald's aunt, Glena Gonzales, later brought him to
the hospital, where he was pronounced comatose and subsequently died on the
evening of September 17, 2009.
The trial court convicted Salve of parricide and sentenced
her to reclusion perpetua based on the testimonies of her children and
medical findings showing that Ronald died from a brain hemorrhage caused by
blunt force trauma. The Court of Appeals affirmed this conviction, prompting
Salve to appeal to the Supreme Court, arguing her innocence and asserting that
Ronald’s injuries were accidental, claiming that he fell from his bed.
Issue:
The primary issue presented to the Supreme Court was whether
Salve Gonzales y Torno was guilty of parricide for the death of her son Ronald,
based on the strength of her children's testimony and the medical evidence.
Ruling of the Supreme Court:
The Supreme Court affirmed the conviction of Salve Gonzales
y Torno. The Court found that the prosecution had proven beyond reasonable
doubt that Salve's repeated assaults on her son using a broomstick and hanger
caused his death. The eyewitness testimonies of her other children, Rhey and
Racel, were deemed credible and consistent with the medical findings.
The Court rejected Salve's defense that Ronald had sustained
his fatal injuries from falling off his bed, finding that such an explanation
was highly improbable. The Supreme Court also denied the plea for mitigating
circumstances, emphasizing that Salve's violent actions were more than
sufficient to cause Ronald's death and reflected a clear intent to harm.
Dispositive Portion:
The Supreme Court denied the appeal and affirmed the
decision of the Court of Appeals with modifications. Salve Gonzales y
Torno was sentenced to reclusion perpetua and ordered to pay the
following amounts to the heirs of Ronald Gonzales:
- P75,000
as civil indemnity
- P75,000
as moral damages
- P75,000
as exemplary damages
- P50,000
as temperate damages
These amounts would accrue interest at 6% per annum from the
finality of the decision until fully paid.
Should the testimony of children against their own parent be
given full weight, even in cases where the outcome leads to a conviction for
such a serious crime like parricide?
Important Doctrines:
- Parricide
under Article 246 of the Revised Penal Code:
Parricide is committed when a person kills his or her father, mother, child (legitimate or illegitimate), or any ascendant or descendant. The penalty for parricide is reclusion perpetua to death. - Credibility
of Child Witnesses:
The Court gives great weight to the testimony of child witnesses, especially when they are testifying against their own parent. It is believed that children would not falsely accuse a parent of a crime as heinous as parricide without compelling reasons. - Denial
as a Weak Defense:
Denial is considered a weak defense, particularly when there is direct and credible eyewitness testimony and supporting physical evidence that contradicts the denial. - Physical
Evidence as Mute Witness:
Physical evidence, such as medical reports and autopsies, often holds more weight than verbal testimony, as it provides objective facts that can either corroborate or contradict a witness's account.
Case Classification:
Criminal Law (Parricide)
From <https://chatgpt.com/g/g-ipZC0xKZ1-case-digest/c/66eeb921-22fc-800a-96ee-e6e24d935fd4>
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🎓 Welcome, law students,
bar reviewers, and legal enthusiasts. In this video, we delve into a deeply
disturbing Supreme Court jurisprudence that explores the boundaries of parental
discipline versus criminal liability. The content will highlight important
doctrines to help law students and future baristas recall and retain
critical rulings and principles from this tragic but legally instructive case.
🧠 The purpose of this
review is to facilitate your mastery of jurisprudence in Criminal Law,
specifically under Article 246 of the Revised Penal Code on Parricide.
⚖️ CASE NATURE: Criminal
Law (Parricide)
CASE TITLE: People of the Philippines v. Salve
Gonzales y Torno
PARTIES: The People of the Philippines
(Plaintiff-Appellee) vs. Salve Gonzales y Torno (Accused-Appellant)
G.R. No.: 217022
DATE PROMULGATED: June 3, 2019
🔍 CASE SUMMARY:
Salve Gonzales was convicted for killing her 13-year-old son
Ronald using a hanger and broomstick. Her own children testified against her.
She claimed the boy fell from a bunk bed, but the Supreme Court found the
physical and testimonial evidence sufficient for parricide. The defense
of denial and the plea for a mitigating circumstance were rejected.
💡 ISSUE: Whether
Salve Gonzales y Torno was guilty of parricide beyond reasonable doubt.
🏛️ SUPREME COURT
DECISION: Conviction affirmed. The Court ruled that the essential
elements of parricide were established—especially the credible eyewitness
accounts of her children and medical evidence. She was sentenced to reclusion
perpetua with damages amounting to ₱275,000.
🗣️ Should children be
encouraged to testify against abusive parents in court—even if it means sending
them to prison for life? Share your thoughts in the comments.
📚 10 DOCTRINES FROM
THE CASE (All citations based on the attached Supreme Court decision,
G.R. No. 217022):
- Definition
of Parricide (Art. 246, RPC):
Parricide is committed when a person kills his/her child, spouse, or ascendant/descendant. [See: p. 19, Decision] - Credibility
of Child Witnesses:
Children’s testimonies against their own parent, when credible and untainted, carry significant weight. [See: pp. 19–20] - Physical
Evidence Prevails Over Denial:
Physical injuries corroborated by medical reports outweigh mere denials. [See: p. 22] - Brute
Force and Continuity of Assault:
The continued use of force, even after the initial object broke, shows intent and cruelty. [See: p. 20] - Denial
is an Inherently Weak Defense:
Especially when overwhelmed by direct, positive, and credible evidence. [See: p. 22] - Lack
of Remorse as Indicator of Intent:
Refusal to bring a dying child to the hospital shows absence of remorse and possible malice. [See: pp. 23–24] - Rejection
of Mitigating Circumstance (Lack of Intent):
Repeated and deliberate acts of violence negate the claim of unintentional harm. [See: pp. 24–25] - Role
of Medical Expert Testimony:
Expert testimony can effectively rule out improbable defense theories, such as accidental fall. [See: p. 21] - Evidentiary
Value of Anatomical Sketch and Medico-Legal Report:
Objective medical findings were consistent with the prosecution’s narrative. [See: p. 21] - Award
of Damages in Parricide Cases:
Civil indemnity, moral, exemplary, and temperate damages were awarded, including interest. [See: p. 26]
📌 DISCLAIMER:
This is an educational video and is not legal
advice. Content is based on official Supreme Court rulings and generated
using premium AI tools. While accuracy is prioritized, we do not
guarantee infallibility. Always consult official sources for bar or legal
use.
🙋♂️ FREQUENTLY ASKED
QUESTIONS (FAQs):
- What
law governs parricide in the Philippines?
→ Article 246 of the Revised Penal Code. - Is
intent to kill required for parricide?
→ Yes, but intent can be inferred from repeated and deliberate acts. - Can
children testify against their parent?
→ Yes. Testimonies from child witnesses are admissible and credible when consistent and untainted. - Can
a claim of accident override physical and medical evidence?
→ No. The Court relies on scientific findings over self-serving claims. - What
is the usual penalty for parricide?
→ Reclusion perpetua to death, but under current law, it usually results in reclusion perpetua.
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From <https://chatgpt.com/g/g-ipZC0xKZ1-case-digest/c/66eeb921-22fc-800a-96ee-e6e24d935fd4>
🎓 INTRODUCTION TO THE
QUIZZER
Welcome, future legal eagles! This quizzer focuses on a
compelling criminal case that reached the Supreme Court of the Philippines — a
tragic and thought-provoking parricide case involving a mother and her son.
This case will test your comprehension, issue-spotting, and understanding of
basic criminal law application.
📌 Case Title: People
of the Philippines v. Salve Gonzales y Torno
📌 Nature: Criminal
Law – Parricide
📌 Parties:
Plaintiff-Appellee – The People of the Philippines; Accused-Appellant – Salve
Gonzales y Torno
📌 Date of
Promulgation: June 3, 2019
Brief Summary:
The case revolves around Salve Gonzales y Torno, who was
convicted for killing her 13-year-old son, Ronald. Eyewitness testimony from
her own children and corroborating medico-legal findings led to her conviction.
The primary issue before the Court was whether her guilt for parricide was
proven beyond reasonable doubt. The Supreme Court affirmed the lower court
rulings, upholding her conviction and rejecting her claim of accident and lack
of criminal intent.
🔑 Stay until the end
of the video for the answer key! Let’s begin.
🔍 HOTS Multiple Choice
Questions – Easy Difficulty
- What
was the relationship between the accused and the victim in this case?
A. Aunt and nephew
B. Mother and son
C. Cousins
D. Step-siblings - What
was the main object used in inflicting fatal injuries to the victim?
A. A belt
B. A stick from a tree
C. A broomstick handle
D. A frying pan - What
event triggered the initial beating of the victim?
A. He stole money
B. He failed school
C. He sold a bronze wire
D. He skipped curfew - Who
among the following testified against the accused?
A. Her boss at work
B. A neighbor
C. Her daughter and son
D. A barangay official - What
best describes the demeanor of the accused after seeing her son vomiting
and weak?
A. She immediately brought him to the hospital
B. She ignored the signs and claimed he was pretending
C. She called a doctor at home
D. She sent him to a rehabilitation center - How
did the accused defend herself in court?
A. Claimed self-defense
B. Claimed someone else committed the act
C. Claimed the child fell from the bed
D. Claimed she was mentally unstable - What
was the ruling of the Court of Appeals before the case reached the Supreme
Court?
A. Acquittal of the accused
B. Conviction for homicide
C. Conviction for parricide
D. Reduction of penalty - What
was the penalty imposed by the Supreme Court on the accused?
A. Death
B. Life imprisonment
C. Reclusion perpetua
D. Community service - Why
was the accused's plea for a mitigating circumstance denied?
A. Because she had prior convictions
B. Because the injuries showed excessive force
C. Because of witness tampering
D. Because she fled the scene - What
form of evidence significantly corroborated the children's testimonies?
A. A CCTV video
B. Medical certificate from a private clinic
C. The autopsy and medico-legal findings
D. Social media posts of the victim
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