G.R. No. 210615 - People vs. Brusola y Baragwa

Accused-appellant Abenir Brusola y Baragwa was charged with the killing of his wife, Delia Brusola y Ramilo, on or about July 12, 2006, in Muntinlupa City, Philippines.
The charge was for parricide under Article 246 of the Revised Penal Code, for willfully and unlawfully hitting the victim on the head with a ball hammer (maso), causing fatal injury.

Abenir was arraigned on August 1, 2006, and pleaded not guilty.
After pre-trial, the case proceeded to trial on the merits.
The Regional Trial Court (RTC), Branch 206, Muntinlupa City, rendered a decision on February 4, 2010, finding Abenir guilty beyond reasonable doubt of parricide and sentencing him to reclusion perpetua. The court awarded his children Php 50,000.00 as indemnity and Php 50,000.00 as moral damages.
Abenir appealed to the Court of Appeals (CA). On July 17, 2013, the CA affirmed the RTC decision in toto.
Abenir filed a notice of appeal to the Supreme Court. The case was elevated, and after due course, both the Office of the Solicitor General and the Public Attorney’s Office declined to file supplemental briefs.

The three children—Joanne, Abegail, and Kristofer Brusola—testified about the incident on July 12, 2006.
Joanne provided a direct eyewitness account, stating that she saw her father hit her mother on the head with a maso without any apparent justification. Abenir then struck the wall a second time.
The siblings indicated that Delia was seated near the toilet watching TV, and after the attack, had a bleeding head and was rushed to the hospital but later died.
Kristofer testified that he saw their father still holding the maso with their mother on the floor bleeding.
Dr. Joseph Palmero, medico-legal officer, testified on the cause of death, confirming the fatal head injury.

Abenir recounted prior incidents of alleged infidelity by Delia, including a previous sighting in 2002 when he saw a shirtless man with his wife at their home in Batangas.
On the night of the killing, he claimed he saw through a crack in the wall a man kissing Delia, who appeared to engage in an affair.
He alleged that in confronting them, the man used Delia as a shield, and during the ensuing scuffle, Delia was accidentally hit by the maso.
Abenir admitted to hitting but argued it was unintentional and claimed he voluntarily surrendered himself to the authorities after the incident.

Whether accused-appellant Abenir Brusola y Baragwa was guilty beyond reasonable doubt of the crime of parricide under Article 246 of the Revised Penal Code.

Whether the Court of Appeals erred in affirming the trial court's decision convicting Abenir without properly considering mitigating circumstances such as passion, obfuscation, and voluntary surrender.

Whether the penalty of reclusion perpetua was correctly imposed in light of mitigating circumstances.