Case Digest (G.R. No. L-17865)
Facts:
The People of the Philippine Islands v. Cipriana Bucsit and Placido Licudine, G.R. No. 17865, March 15, 1922, the Supreme Court (Malcolm, J., writing for the Court; Araullo, C.J., Avancena, Villamor, Ostrand, Johns, and Romualdez, JJ., concurring).The criminal episode involved Cipriana Bucsit (wife) and her paramour Placido Licudine, who had carried on an illicit relationship and conspired to kill Cipriana’s husband, Pastor Pagaduan, so that the conspirators might marry. According to the factual findings, Licudine prepared poison and mixed it into the morisqueta (a food) which the husband ate; the husband died and the family dog, having eaten some of the same food, also died. Licudine attempted to cover up the crime by returning from the fields and reporting the husband’s death as if he had just found the body.
The father-in-law recovered the body and notified municipal authorities. Dr. Querol, President of a sanitary division in La Union, examined the remains and reported that death resulted from poisoning. An investigation followed and both accused executed extrajudicial confessions in the local dialect, in the presence of witnesses, and swore to those statements before a notary public. They later answered “Si, senor, somos culpables” when asked their guilt by the justice of the peace of Bacnotan. The confessions and plea of guilty were corroborated by other reliable witnesses, including the woman’s father.
At trial the judge convicted Cipriana Bucsit of parricide and sentenced her to reclusion perpetua; the court found the aggravating circumstance of poisoning but concluded that the mitigating circumstance under Article 11 of the Penal Code, as amended applied. Placido Licudine was convicted of murder with the qualifying circumstance of killing by means of poisoning; the trial judge found no aggravating or mitigating circumstances and imposed seventeen years, four months and one day of cadena temporal, plus joint and several indemnity of P1,000 to the heirs and costs. The de...(Subscriber-Only)
Issues:
- Did the evidence (confessions, medical opinion, witness testimony) sufficiently establish beyond reasonable doubt that Cipriana Bucsit and Placido Licudine caused the death of Pastor Pagaduan?
- What are the proper penalties for Cipriana Bucsit (parricide) and Placido Licudine (murder) in light of the qualifying/aggravating circumstance of poisoning and the mitigating provision of Article ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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