G.R. No. 204766 - Department of Health vs. Aquintey

On November 4, 1938, in the accused’s residence, a tragic incident occurred resulting in the death of three members of his immediate family.
The victims included Beling (the accused’s wife) and his two young children: four-year-old Paya and six‑month‑old Trinidad, also known as Sinanga.

Government agents arrived promptly at the scene, with the first being Constabulary Sergeant Ignacio Bersamina and Tugboc’s health inspector, Agustin Candia.
The accused, upon confronting these authorities, admitted that he had killed his wife and children, attributing his actions to a burst of rage.

In the afternoon of the same day, the accused, sustaining some wounds, was rushed to Davao Public Hospital.
On November 5, 1938, while being questioned by the fiscal in the presence of Lieutenant Villares, deputy clerk Mr. Frias, and Sergeant Bersamina, the accused reaffirmed his earlier confession by stating he had killed his wife and children and had wounded himself.

The testimony of Mora Bayna, the accused’s mother, was pivotal. She testified that she witnessed her son strike Paya with bolo blows.
Bayna also stated that she saw Beling wrest the bolo from the accused and, amid the struggle, wound her own child Sinanga, casting doubt on the precise manner of Trinidad’s death.
The court noted discrepancies in the narrative, particularly regarding whether the accused or Beling was responsible for the injuries on Sinanga, concluding that the accused might have been uncertain in recollection.

In one case, he was acquitted.
In a second case, he was found guilty of killing Beling and Paya, with the crime committed against Beling classified as homicide due to the lack of unequivocal evidence of a marital relationship.
In a third case, he was charged with parricide for the death of his daughter Paya.

In the homicide case, the court imposed an indeterminate penalty ranging from six (6) months and one (1) day of prision mayor to twelve (12) years and one (1) day of reclusion temporal, along with a P2,000 indemnity to the heirs of Beling.
In the parricide case, the accused was sentenced to reclusion perpetua, and was also held liable for court costs, with no indemnity pronouncement for Paya’s death due to his status as her presumptive heir.

His guilt had not been established beyond a reasonable doubt.
The testimony of his mother, Mora Bayna, was contradictory.
He could not read his own declaration properly when it was recited by the fiscal, and he had not conversed with Sergeant Bersamina as suggested.

The accused presented an alternate narrative stating that he was asleep on November 4, 1938, and was wounded by Beling. Upon awakening, he allegedly found his daughter Paya dead beside him and, noticing that Beling was holding a bolo, took it from her and delivered bolo blows out of pity for his children.

Whether the evidence presented, including the confession and the testimonies of key witnesses, sufficiently established the accused’s guilt beyond reasonable doubt.
The issue of conflicting testimonies, particularly the account provided by Mora Bayna regarding the sequence of events during the fatal incident.

The reliability of the accused’s confession versus the alternative version he later presented.
The apparent inconsistencies between the account of the accused and the observational evidence provided by witnesses, notably regarding the cause of injuries sustained by Trinidad (Sinanga).

Whether the killing of Beling, despite being his wife with questionable proof of marriage, should be considered homicide rather than parricide.
The appropriate legal characterization and subsequent sentencing for the killing of his daughter Paya.