G.R. No. 172693 - People vs. Solangon

Spouses Wenceslao Alcansare and Natividad Luague were charged with homicide in the Court of First Instance of Occidental Negros.
They were sentenced: Wenceslao to 8 years and 1 day of prision mayor minimum up to 14 years, 8 months, and 1 day of reclusion temporal maximum; Natividad to 6 years and 1 day of prision mayor minimum up to 12 years and 1 day of reclusion temporal maximum. Both were ordered to indemnify the heirs of Paulino Disuasido Php 1,000.

On the morning of February 18, 1935, Natividad Luague was home alone with her three young children; her husband Wenceslao was several kilometers away grinding corn.
Paulino Disuasido came to Natividad’s house and began making love advances despite her refusals.
When she went to the kitchen, Paulino followed, threatened her with a knife, embraced her forcibly, and attempted to lie with her.
Paulino left the knife on the floor during the assault; Natividad took it and stabbed him in the abdomen.
Paulino fled by jumping through the window, falling on stones.
Natividad immediately surrendered herself to authorities to report the incident.

The prosecution alleged Wenceslao, out of jealousy, conspired with Natividad to kill Paulino.
It was argued that Natividad invited Paulino and his companion Olimpio Libosada, borrowed Paulino’s knife under false pretenses, and stabbed him while he was distracted.
Wenceslao supposedly struck Paulino with a stone during the incident.
Witness Pablo Alvarez testified that he had prior knowledge of Wenceslao’s plans to avenge himself on Paulino and that the spouses acted jointly.
Other witnesses, Angel Emia and Olimpio Libosada, claimed to have seen the stabbing but their statements had inconsistencies.

The defense contended Natividad acted alone in legitimate self-defense to protect her honor against an attempted rape.
The Court noted that the prosecution witnesses’ testimonies were contradictory or inherently unbelievable:

Alvarez’s conduct was inconsistent with his claim that he was informed of the attack.
Emia disclaimed knowledge about who stabbed Paulino in a previous statement.
Libosada did not assist Paulino during the attack and fled the scene without reporting it.

The trial court put significant weight on police testimony that no bloodstains were found inside the kitchen. However, the Court found this testimony equivocal because no blood was found on the threshold of the house as well, which contradicted both parties’ versions.
The Court found no convincing evidence of conspiracy or Wenceslao’s participation.

Whether the killing of Paulino Disuasido by Natividad Luague constitutes homicide or is protected by the exempting circumstance of legitimate self-defense under Article 11, subsection 1, of the Revised Penal Code.
Whether Wenceslao Alcansare participated in the killing and is also liable.
Whether the evidence presented by the prosecution is sufficient to uphold the conviction of the accused spouses.