G.R. No. 189834 - People vs. Maglian y Reyes

Charge and Procedural History
On January 4, 2000, an Information was filed in RTC Branch 22, Imus, Cavite, charging Jay Mandy Maglian y Reyes with parricide for pouring kerosene on and setting fire to his lawfully wedded wife Mary Jay Rios Maglian, resulting in her death.
The accused pleaded “not guilty.” On May 8, 2006, the RTC convicted him of parricide and sentenced him to reclusion perpetua, ordering civil indemnities. On December 23, 2008, the CA in CA-G.R. CR-H.C. No. 02541 affirmed the RTC decision.

Factual Circumstances of the Incident
On January 4, 2000, the couple argued at home in Dasmariñas, Cavite. Incensed, the accused doused his wife and her clothes with kerosene and ignited them, causing 90% third-degree burns on her body.
The victim was treated at De La Salle University Medical Center, transferred to East Avenue Medical Center (burn unit), then to St. Claire Hospital, and finally to PGH, where she died on February 24, 2000. Before expiring, she declared to her mother and their laundrywoman, “Si Jay Mandy ang nagsunog sa akin.”

Evidence at Trial
Prosecution witnesses: Lourdes Rios (mother), Norma Saballero (laundrywoman), Dr. Ludovino Lagat, Amy Velasquez, and PO3 Celestino San Jose. They testified to the victim’s dying declaration implicating the accused.
Defense witnesses: the accused; Atty. Ma. Angelina Barcelo; Atty. Rosemarie Perey-Duque; PO3 San Jose (on behalf of defense); and Lourdes Panopio. They presented an accident theory and an alternate dying declaration allegedly absolving the accused.

Whether the guilt of accused-appellant has been proven beyond reasonable doubt, specifically:
Whether he intended to kill or to commit so grave a wrong as to cause his wife’s death.
Whether he is entitled to the mitigating circumstance of voluntary surrender.