Case Digest (G.R. No. 107801)
Case Digest (G.R. No. 107801)
Facts:
People of the Philippines v. Rosaria V. Ignacio, G.R. No. 107801, March 26, 1997, the Supreme Court First Division, Vitug, J., writing for the Court.The accused-appellant, Rosaria V. Ignacio, was charged with parricide in the Regional Trial Court of Rizal, Branch 76 (Criminal Case No. 1700), after an information filed on February 19, 1992 alleged that on or about February 10, 1992 she willfully, unlawfully and feloniously struck her lawfully wedded husband, Juan Ignacio, with a wooden club (palo-palo), inflicting injuries which directly caused his death. Rosaria pleaded not guilty.
The prosecution's account was that on the evening of February 10, 1992 Rosaria and Juan engaged in a quarrel; Rosaria's daughter, Milagros, heard a violent scuffle, saw the couple pulling at a piece of lawanit and then saw Rosaria pick up a palo-palo and hit Juan on the nape. Rosaria thereafter went to the municipal hall and voluntarily told Rolando Ignacio (the deceased’s son) and Patrolman San Diego that she had struck Juan; she repeated the admission at the Office of the Prosecutor in Marikina. Juan died the following day. Dr. Emmanuel Aranas performed the postmortem, finding contusions and a laceration on the skull, fractured cranial bones and hemorrhage; the autopsy attributed death to hemorrhage from traumatic head injuries.
At trial Rosaria did not deny inflicting the fatal blow. She testified that Juan, drunk and armed with a bolo, circled the bed and threatened her; she claimed she struck him once with a palo-palo in self-defense. No witnesses were offered in support of self-defense other than her testimony. Milagros’s testimony, however, related that Juan was weak from intoxication and that Rosaria struck him as he was only about to get his bolo. The alleged bolo was never produced.
On September 8, 1992 the trial court convicted Rosaria of parricide under Article 246 of the Revised Penal Code and sentenced her to reclusion perpetua, ordering indemnity of P30,000.00. Rosaria appealed, arguing primarily that she acted in self-defense and alternatively that she should be convicted only of homicide because there was no clear evidence of marriage to sustain parricide. The case was brought to the Supreme Court for review, where the First Division resolved the appeal.
Issues:
- Did the accused prove self-defense as a justifying circumstance excusing criminal liability?
- Was the conviction properly for parricide rather than a lesser crime (homicide) given the evidence of marital relationship?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)