Case Digest (A.M. No. P-21-4100) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The People of the Philippines vs. Jesus Paycana, Jr., appellant was charged before the Regional Trial Court of Iriga City, Branch 37, with the complex crime of parricide and unintentional abortion for stabbing his seven-month pregnant wife, Lilybeth Balandra-Paycana, on November 26, 2002, at Sitio Sogod, Sto. Domingo, Nabua, Camarines Sur. Appellant pleaded not guilty but later invoked self-defense, admitting Lilybeth was his lawful spouse. Prosecution witnesses included Tito Balandra (victim’s father), Angelina Paycana (the couple’s eldest daughter and eyewitness), Barangay Tanod Juan ParaAal Jr., Dr. Stephen Beltran (autopsy surgeon), and embalmer Santiago Magistrado Jr. They testified that around 6:30 a.m. appellant, a butcher, arrived home armed with a kitchen knife and bolo and stabbed Lilybeth fourteen times without provocation. Angelina’s immediate report to her grandfather and Tito’s observation of the victim’s trembling body contradicted any defensive struggle. On Ap Case Digest (A.M. No. P-21-4100) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Pre-trial and charges
- Appellant Jesus Paycana Jr. was charged before the RTC of Iriga City, Branch 37, with the complex crime of parricide with unintentional abortion; he pleaded not guilty but admitted that the victim, Lilybeth Balandra-Paycana, was his legitimate wife.
- He claimed self-defense, alleging that on 25 November 2002 his wife attacked him first with a knife, which he wrested from her before stabbing her.
- Facts of the killing
- On 26 November 2002 at around 6:30 AM, appellant returned home armed with a kitchen knife, a bolo, and a sharpener; for reasons known only to him, he stabbed his seven-month pregnant wife 14 times, causing her immediate death and the death of the fetus.
- Eyewitnesses:
- Eldest daughter Angelina saw her father strangle and stab her mother despite her pleas.
- Victim’s father Tito heard screams, saw appellant armed and the victim prostrate with trembling feet; Angelina then told Tito by the window that appellant had stabbed her mother.
- Dr. Stephen Beltran conducted the autopsy confirming multiple fatal stab wounds; Santiago Magistrado Jr. embalmed the body and removed the fetus.
- Procedural history
- The RTC convicted appellant on 14 April 2005 and imposed the death penalty, civil indemnity, moral and exemplary damages.
- The Court of Appeals denied his appeal on 30 May 2007, commuted the penalty of death to reclusion perpetua under R.A. 9346, and affirmed civil liabilities. Appellant’s appeal to the Supreme Court followed.
Issues:
- Whether appellant proved the justifying circumstance of self-defense.
- Whether the factual findings on unlawful aggression and necessity of means should be disturbed.
- Whether the killing constitutes a complex crime of parricide with unintentional abortion.
- Whether the penalty of reclusion perpetua and civil liabilities are proper under the RPC and R.A. 9346.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)