G.R. No. L-23867 - Pagtakhan vs. Court of Industrial Relations

On August 19, 2005, the City Prosecutor of Tacloban filed an Information charging William Sabalberino y Abulencia with the crime of parricide for stabbing his wife, Delia Fernandez-Sabalberino.
The stabbing took place on August 17, 2005, in Tacloban City, where William allegedly stabbed Delia in the chest and heart with a knife, causing her death.
Upon arraignment on March 21, 2006, accused-appellant pleaded not guilty.

William and Delia were lawfully married and had five children: Wendel, Wedylyn, William, Angela, and Jessica.
William worked as a painter, and Delia as a laundrywoman. They lived together in Barangay 59, Picas, Sagkahan, Tacloban City.

Around 1:00 AM on August 17, 2005, Angela and Jessica were awakened by their parents’ shouting and arguing.
During the quarrel, William punched Delia’s face. Angela and Jessica intervened by hugging their mother.
William then went to the kitchen, retrieved a knife, and stabbed Delia below her armpit while she was holding the children.
Delia attempted to walk to the door but collapsed before reaching it and died shortly after.
William did not deny stabbing Delia but claimed it was accidental during an altercation involving another man.

William alleged that on August 16, 2005, he took a nap and only woke up around midnight. Upon leaving the bedroom to urinate, he saw his wife half-naked with a fully naked man on top of her.
He retrieved a knife, confronted them, and grappled with the man in an attempt to stab him; however, his wife intervened and was accidentally stabbed instead.
The man fled through the window; William claimed the stabbing was not intentional against Delia.
He asked his children to call for help, but Delia succumbed to her injuries before receiving aid.

The Regional Trial Court (RTC) of Tacloban City found William guilty of parricide beyond reasonable doubt and sentenced him to reclusion perpetua.
The RTC ordered William to pay P75,000 as civil indemnity and P50,000 as moral damages to the heirs of the victim.
The RTC rejected William’s claim of accidental stabbing, giving credence to the children’s consistent testimonies denying the presence of the alleged man and confirming the quarrel preceding the fatal stabbing.

William appealed, reiterating his defense under Article 247 of the Revised Penal Code (RPC) that he caught his wife committing adultery and that the stabbing was accidental.
He also argued the mitigating circumstances of passion, voluntary surrender, and lack of intent to impose a lesser penalty.
The CA affirmed the conviction but modified the damages award, increasing moral damages to P75,000, adding temperate damages of P50,000, and exemplary damages of P75,000, all with interest at 6% per annum.
The CA denied William’s Motion for Reconsideration.

William filed a Notice of Appeal to the Supreme Court, adopting his previous briefs.
The Office of the Solicitor General also adopted its appellee’s brief before the CA and prayed for the affirmation of the conviction.
The main issue before the Supreme Court was whether the CA correctly upheld William’s conviction for parricide.

Whether the elements of the crime of parricide were proven beyond reasonable doubt.
Whether the accused-appellant’s defense under Article 247 of the RPC, alleging the killing occurred upon discovering his wife committing sexual intercourse with another man, was valid and supported by evidence.
Whether the mitigating circumstances invoked by the accused-appellant—passion and obfuscation, voluntary surrender, and lack of intention to commit so grave a wrong—were sufficiently established to warrant reduction of penalties.
Whether the penalty and damages imposed by the RTC and modified by the CA were proper.