Facts:

The case involves Pedro Malabago y Villaespin, the accused-appellant, who was charged with parricide for the murder of his wife, Letecia R. Malabago. The incident occurred on January 5, 1994, in Barangay Gulayon, Dipolog City, Philippines. The prosecution's account states that at around 7:00 PM, Letecia was outside her mother Guillerma Romano's sari-sari store after selling jackfruit. An argument erupted between Letecia and Pedro, which escalated into violence. Guillerma, who was present, heard a loud noise and initially thought it was a slap. However, she soon witnessed Pedro attacking Letecia with a bolo, inflicting severe injuries that led to her immediate death. After the incident, Pedro fled to a nearby house, and the police were called to apprehend him. A bloodied bolo was later found in a nearby pineapple plantation. Letecia's death was confirmed to be due to multiple hack wounds. Pedro pleaded not guilty, claiming he was elsewhere during the incident and s...

Facts:

Incident Details

• On January 5, 1994, at around 7:00 PM, Guillerma Romano, the mother-in-law of accused-appellant Pedro Malabago, was tending her sari-sari store in Barangay Gulayon, Dipolog City. The store was lit by a kerosene lamp and a fluorescent light from a nearby house.
• Letecia Romano Malabago, the wife of Pedro Malabago, arrived and sat on a bench outside the store. She had just returned from selling jackfruit. Her 14-year-old son, Allandel, joined her.
• Pedro Malabago arrived and interrupted the conversation between Letecia and Guillerma. An argument ensued between Pedro and Letecia over money and Pedro's jealousy of someone.
• Suddenly, Guillerma heard a loud sound, which she thought was a slap. She then saw Letecia's face bloodied with a slash on her right ear. Pedro, holding a bolo, struck Letecia again, hitting her lower left face and neck. Letecia fell to the ground and died instantly.
• Guillerma rushed to her daughter and shouted for help. Pedro fled to a nearby house, where he was later fetched by the police.

Investigation and Evidence

• The police found a bloodied bolo in a pineapple plantation near Pedro's house.
• The death certificate of Letecia indicated she died of "cardio-respiratory arrest; shock hemorrhage, massive; hack wounds, multiple."
• Pedro was charged with parricide under Article 246 of the Revised Penal Code, as amended by Republic Act No. 7659.

Defense

• Pedro pleaded not guilty, claiming he was in Dipolog City's poblacion at the time of the incident and did not know who killed his wife.
• He alleged that Guillerma testified against him because she opposed their marriage.
• Guillerma, along with her husband and Pedro and Letecia's three children, later signed an affidavit of desistance, seeking to dismiss the case.

Issue:

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Ruling:

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Ratio:

1. Parricide Elements: The crime of parricide requires the killing of a spouse, ascendant, descendant, or child. The key element is the relationship between the accused and the victim. In this case, Pedro admitted under oath that Letecia was his wife, which established the marital relationship.
2. Cause of Death: The prosecution sufficiently proved Letecia's death through Guillerma's testimony and the death certificate. Pedro's admission that his wife died from hacking also corroborated the cause of death.
3. Trial Court's Role: The trial judge's intervention in questioning witnesses was within his discretion to clarify facts and expedite the trial. There was no violation of due process.
4. Credibility of Witnesses: Guillerma's testimony was credible despite minor inconsistencies. Her affidavit of desistance was signed under pressure from her grandchildren, but she still testified for the prosecution.
5. Alibi Defense: Pedro's alibi was weak and unconvincing, as he was positively identified at the scene of the crime.
6. Treachery: Treachery was not proven because the attack occurred during a sudden argument, not as a premeditated act.
7. Voluntary Surrender: Pedro voluntarily surrendered to the police, which was a mitigating circumstance.
8. Civil Indemnity: The Court awarded P50,000 as civil indemnity for Letecia's death.

Conclusion:

The Supreme Court upheld Pedro Malabago's conviction for parricide but reduced the penalty to reclusion perpetua due to the mitigating circumstance of voluntary surrender. The Court found no treachery and awarded civil indemnity to the victim's heirs.