Case Digest (G.R. No. 187683)
Facts:
People of the Philippines charged Victoriano dela Cruz y Lorenzo with Parricide in an Information dated January 2, 2003, for the killing of his wife, Anna Liza Caparas-dela Cruz, on August 18, 2002 in Malolos, Bulacan. Witness Joel saw Victoriano assault the victim, who was later taken to Bulacan Provincial Hospital and whose Medico-Legal Report showed a penetrating stab wound that lacerated the upper lobe of the right lung; the RTC convicted Victoriano on August 15, 2005 and the CA affirmed with modification on October 31, 2008.Victoriano appealed to this Court contesting the sufficiency of the evidence, claiming accident and intoxication as defenses, and contesting the damages awards.
Issues:
- Was the conviction for Parricide under Article 246, Revised Penal Code supported beyond reasonable doubt by the evidence?
- Did the defense of accident negate criminal liability?
- Did voluntary intoxication mitigate appellant's criminal liability?
- Were the awards of civil indemnity,
Case Digest (G.R. No. 187683)
Facts:
- Parties and procedural posture
- PEOPLE OF THE PHILIPPINES, APPELLEE, filed Information dated January 2, 2003, charging VICTORIANO DELA CRUZ Y LORENZO, APPELLANT, with Parricide.
- The Information alleged that on or about August 18, 2002, in Malolos, Bulacan, appellant with intent to kill his wife Anna Liza Caparas-dela Cruz stabbed her causing death.
- Appellant arraigned and pleaded not guilty; trial on the merits followed.
- The Regional Trial Court (RTC), Branch 11, Malolos, Bulacan, rendered judgment on August 15, 2005, finding appellant guilty of Parricide and sentencing him to reclusion perpetua and awarding P60,000.00 civil indemnity, P50,000.00 moral damages, and P30,000.00 exemplary damages.
- Appellant appealed to the Court of Appeals (CA), which on October 31, 2008, affirmed with modification, reducing civil indemnity to P50,000.00 and deleting exemplary damages.
- Appellant elevated the case to the Supreme Court by way of appeal.
- Prosecution version and evidentiary record
- Witness Joel Song testified he and two others were playing tong-its near appellant’s house between 3:30 and 4:00 p.m. on August 18, 2002, about three to four arm’s lengths away.
- Joel saw appellant punching and kicking his wife, then dragging her inside the house by the hair while they shouted.
- Joel saw the couple emerge with their young daughter; appellant was behind the wife with arms around her and blood was spurting from the wife’s mouth.
- Joel took the daughter to appellant’s aunt and accompanied appellant and the injured wife to Bulacan Provincial Hospital on a tricycle.
- Senior Police Officers Condrado Umali and Eligio Jose went to the hospital about 6:30 p.m.; hospital security turned appellant over to police for investigation.
- Police Senior Inspector and Medico-Legal Officer Dr. Ivan Richard Viray prepared the Certificate of Death and Medico-Legal Report dated August 21, 2002, indicating cause of death as “hemorrhagic shock as a result of a stab wound, trunk.”
- Dr. Viray’s findings included multiple hematomas on head and neck; a penetrating stab wound in right shoulder region measuring 2 x 0.5 cm, about 12 cm deep, lacerating the upper lobe of the right lung; approximately 2000 cc of blood and clots in the thoracic cavity; and hematoma with abrasion on left forearm.
- Def...(Subscriber-Only)
Issues:
- Guilt and sufficiency of evidence
- Whether the prosecution proved beyond reasonable doubt that appellant killed his spouse and thus committed Parricide under Art. 246 of the Revised Penal Code (RPC).
- Whether the testimony of witness Joel Song and Dr. Viray’s Medico-Legal Report constituted sufficient direct or circumstantial evidence to convict appellant.
- Defenses and mitigating circumstances
- Whether appellant’s claim that the injury resulted from an accident absolved him of criminal liability under Article 12, paragraph 4, RPC.
- Whether appellant’s intoxication at the time of the incident qualified as mitigating circumstance to r...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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