Case Digest (G.R. No. 135981) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In en banc People of the Philippines v. Marivic Genosa (G.R. No. 135981, January 15, 2004), the Supreme Court reviewed the September 25, 1998 RTC Decision of Branch 35, Ormoc City in Criminal Case No. 5016-0, which found appellant Marivic Genosa guilty beyond reasonable doubt of parricide under Article 246 of the Revised Penal Code as amended by RA 7659 and sentenced her to death with indemnities and moral damages. Appellant, a port manager’s secretary in Ormoc City, was married to Ben Genosa on November 19, 1983, and they had three children. On November 15, 1995 at their rented residence in Barangay Bilwang, Isabel, Leyte, the deceased, returning drunk from the cockpit, twice beat and threatened his eight-month pregnant wife—first dragging and strangling her with a bolo, then, after she temporarily escaped to the children’s room, returning to retrieve a cutter and menacing her near a locked drawer containing a firearm. Believing her life and that of her unborn child to be in im Case Digest (G.R. No. 135981) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- RTC of Ormoc City, Branch 35, found Marivic Genosa guilty beyond reasonable doubt of parricide (Art. 246, RPC) with treachery as aggravating circumstance and imposed the death penalty.
- On automatic review before the Supreme Court, appellant invoked a novel self-defense theory—“battered woman syndrome” (BWS)—and sought remand for expert psychological testimony.
- Background and Fatal Incident
- Marriage and family.
- Appellant married Ben Genosa in 1983; they had three children and lived in Leyte.
- From 1989 to 1995, appellant suffered repeated episodes of domestic violence—documented in six medical records—each following husband’s drunken gambling or womanizing.
- Events of November 15–16, 1995.
- Husband returned home drunk, cut the TV antenna with a bolo, grappled and whirled appellant, dragged her by the neck toward a drawer holding his gun.
- Appellant struck him with a metal pipe, ran to the children’s room, but perceived ongoing danger to her and her eight-month fetus; retrieved the gun and shot him.
- Discovery and postmortem.
- On November 18, neighbors reported a foul odor; police and doctor found the corpse in advanced decomposition, with a depressed occipital fracture causing fatal intracranial hemorrhage.
- Postmortem estimated death occurred two to three days earlier.
- Expert remand.
- Supreme Court remanded for examination by psychologists/psychiatrists on BWS.
- Dr. Natividad Dayan and Dr. Alfredo Pajarillo testified on appellant’s cyclic abuse, learned helplessness, post-traumatic stress, diminished self-control and heightened fear.
Issues:
- Whether appellant acted in lawful self-defense (or defense of her unborn child) under the Revised Penal Code.
- Whether the “battered woman syndrome” justified or mitigated criminal liability.
- Whether the killing was attended by treachery.
- Whether other factual objections (marriage proof, manner of death, victim’s character, failure to call children, flight to Manila) warrant reversal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)