Case Digest (G.R. No. 179035)
Facts:
The People of the Philippines v. Jesus Paycana, Jr., G.R. No. 179035, April 16, 2008, the Supreme Court Second Division, Tinga, J., writing for the Court. The appellant is Jesus Paycana, Jr.; the appellee is The People of the Philippines.Appellant was charged before the Regional Trial Court (RTC) of Iriga City, Branch 37, with the complex crime of parricide with unintentional abortion for stabbing to death his seven‑month pregnant wife, Lilybeth Balandra‑Paycana. At arraignment appellant pleaded not guilty; during pre‑trial he admitted that Lilybeth was his legitimate wife. The prosecution presented, among others, Tito Balandra (victim’s father), appellant’s eldest daughter Angelina (an eyewitness), a barangay tanod, and pathologists/embalmer who handled the body and removed the fetus. Appellant pleaded self‑defense, claiming his wife stabbed him first and he wrested the knife away before stabbing her.
Trial evidence placed the incident on 26 November 2002 at about 6:30 a.m.; appellant returned from work armed with cutting tools and allegedly stabbed his wife fourteen times. Angelina testified she witnessed her father strangle and repeatedly stab her mother; she immediately told her grandfather that appellant had stabbed Lilybeth (admitted as part of the res gestae). Tito likewise testified he heard screams, saw Lilybeth prostrate and appellant armed. A defense medical witness, Dr. Rey Tanchuling, who treated appellant’s wound, on cross‑examination conceded appellant’s injuries were possibly self‑inflicted and only superficial.
The RTC rendered judgment on April 14, 2005, finding appellant guilty beyond reasonable doubt and sentencing him to death (with damages). Because the RTC had imposed death, the record was automatically forwarded to the Court of Appeals under the amended Rules of Criminal Procedure (A.M. No. 00‑5‑03‑SC, Rule 122, Secs. 3(d), 10). The Court of Appeals, in a decision dated May 30, 2007, affirmed the conviction but modified the penalty from death to reclusion perpetu...(Pro-only)
Issues:
- Did the trial court err in rejecting appellant’s plea of self‑defense and convicting him of parricide with unintentional abortion?
- Were the elements of parricide and unintentional abortion established and were the penalties and damages properly impose...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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