G.R. No. 46530 - People vs. Rabao

The case involves the People of the Philippines as Plaintiff and Appellee versus Catalino Rabao as Defendant and Appellant.
The defendant was married to Salvacion Agawa on January 15, 1936, before a justice of the peace in Naga, Camarines Sur.
The couple had a child of tender age and made their home in the residence of Urbano Rellora, who was in a marital relationship with the mother of the accused.

On the morning of December 15, 1937, after a sleepless night due to municipal election celebrations, the defendant was barely awake.
The defendant observed his wife preparing water to bathe their child.
A quarrel ensued when the defendant ordered his wife not to bathe the child (citing the child’s cold) while she insisted on proceeding, which escalated the altercation.
During the quarrel, the defendant punched his wife on the abdomen.
As a consequence of the blow, the victim fell, landing on a sack of rice, and immediately suffered an attack that led to her rapid deterioration and eventual death.

The victim’s spleen was hypertrophied due to acute and chronic malaria.
The death was caused by hemorrhage from the rupture of the spleen, which was attributed to an external blow to the abdomen.

Urbano Rellora, the owner of the house, testified that he witnessed the defendant punching his wife on the abdomen, leading her to fall and suffer an immediate attack.
The defendant’s own sworn declaration admitted that he struck his wife with his fist following verbal provocation.
An additional eyewitness, Raymundo Hilano, claimed to have seen and heard the incident, although his testimony was later considered less credible due to the distance and angle of observation.

The incident was charged as parricide under Article 246 of the Revised Penal Code.
Mitigating circumstances noted by the lower court included:

Lack of intention to commit a grave crime (Article 13 [3], Revised Penal Code).
Acting under an impulse that naturally produced passion or obfuscation (Article 13 [6]).
Immediate surrender to authority after the offense (Article 13 [7]).
The absence of any aggravating circumstances.

The penalty originally imposed by the Court of First Instance of Camarines Sur was an indeterminate sentence ranging from eight years and one day of prision mayor to twenty years of reclusion temporal, along with accessory penalties and indemnification to the heirs of the deceased.

The defense contended that the lower court erred by finding that the blow to the abdomen directly caused the death, suggesting instead that the defendant should have been found guilty of parricide through reckless imprudence.
They argued that the act was not a deliberate lethal assault but rather the result of an impulsive response lacking the requisite intent for parricide.

Whether the trial court correctly found that the defendant’s act of punching his wife on the abdomen was the direct cause of her death.

This includes assessing if the physical blow was sufficient to rupture the spleen and produce a fatal hemorrhage.
Determining the credibility and weight of corroborative testimonies from Urbano Rellora, the defendant’s sworn admission, and the contested testimony of Raymundo Hilano.

Whether the evidence supports conviction for parricide as committed by direct physical aggression, as opposed to an offense characterized merely by reckless imprudence.

Evaluating the applicability of Article 365 of the Revised Penal Code related to reckless imprudence, which requires that the underlying act be lawful.
Considering whether the mitigating circumstances justify a downscaled penalty, shifting the imposition towards reclusion perpetua rather than a harsher penalty prescribed for parricide.

The proper determination and application of penalty in light of the mitigatory factors.

Assessing if the imposition of an indeterminate penalty was consistent with the provisions of Article 246 (crime of parricide) and Article 63, Rule 3 of the Revised Penal Code.
Whether the mitigating circumstances adequately warranted a reduction in the penalty from reclusion perpetua (or death) to a more lenient sentence.