Case Digest (G.R. No. 18600)
Facts:
In People of the Philippines vs. Manuel Macal y Bolasco, G.R. No. 211062, decided on January 13, 2016, the accused-appellant, Manuel Macal y Bolasco, was charged by Information dated February 13, 2003 with parricide for the fatal stabbing of his lawful wife, Auria Ytac Macal, inside their bedroom in V & G Subdivision, Tacloban City, on February 12, 2003. Upon arraignment on July 7, 2003, he pleaded not guilty. The prosecution presented Angeles Ytac (the victim’s mother) and Erwin Silvano, who testified that they heard Auria’s plea for help and later saw Auria bleeding and the accused attempting self-stab. A Certificate of Death established her demise by hemorrhagic shock from a stab wound. The defense testified through the accused, Benito Billota, and Nerissa Alcantara that the stabbing was accidental and aimed at a man allegedly in the room shielding Auria. The Regional Trial Court of Tacloban City, Branch 6, on August 18, 2009, found Macal guilty beyond reasonable doubt of par...Case Digest (G.R. No. 18600)
Facts:
- Parties and Background
- Accused-appellant Manuel Macal y Bolasco and victim Auria Ytac Macal married in March 2000 in Manila; they had two children (one deceased).
- The couple resided with Auria’s mother, Angeles Ytac, in V & G Subdivision, Tacloban City; accused worked in Manila and returned home annually.
- Circumstances of the Killing
- On February 12, 2003 at around 1:20 AM, Angeles and her children returned from bingo to their house with friends. Auria and accused joined them to the threshold and then went to their bedroom four meters away.
- Auria screamed “Mother help me, I am going to be killed.” The locked bedroom door was kicked open. Witnesses saw Auria bloodied on the floor and accused attempting self-stabbing with a belt buckle; Auria was declared dead on arrival at the hospital. Accused fled over the fence.
- Trial Proceedings
- February 13, 2003: Information for parricide filed; accused pleaded not guilty on July 7, 2003. Parties stipulated to the spousal relationship at pre-trial.
- Prosecution witnesses Angeles Ytac and Erwin Silvano testified to Auria’s screams, the locked door, the stabbing of Auria by accused, and his self-inflicted wounds. Certificate of Death admitted.
- Defense witnesses included accused, Benito Billota, and Nerissa Alcantara. Accused admitted the stabbing but claimed he aimed at a man in the room and that Auria shielded him, making the injury accidental; he also wounded himself out of desperation. Nerissa authenticated hospital records of accused’s chest wounds.
Issues:
- Guilt of Parricide
- Whether the prosecution proved beyond reasonable doubt all elements of parricide under Article 246, RPC.
- Applicability of Exempting/Absolutory Circumstances
- Whether the defense of accident under Article 12(4), RPC, exonerates accused.
- Whether Article 247, RPC (spouse caught in act of intercourse) absolves him of liability.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)