Case Digest (G.R. No. 124303-05)
Facts:
People of the Philippines v. Cristina Samson, G.R. No. 214883, September 02, 2015, Supreme Court Second Division, Mendoza, J., writing for the Court. The plaintiff-appellee is the People of the Philippines and the accused-appellant is Cristina Samson.On August 14, 2002 an Information charged Cristina with parricide under Article 246 of the Revised Penal Code for stabbing her husband, Gerry Delmar, on June 27, 2002. When arraigned nearly four years later, Cristina pleaded not guilty. Trial on the merits proceeded as a reverse trial because Cristina asserted the justifying circumstance of self‑defense.
Cristina’s account (as presented in her brief and testimony) was that Gerry arrived drunk, demanded food, scolded and slapped her, and pointed a knife at her throat. Her father briefly pacified them; Gerry left but returned, again threatening her with the knife. Cristina pushed him; he fell and she took hold of the knife he had been holding, pointed it at him and implored him not to come nearer. Gerry then grabbed her arm and, in the ensuing struggle, the knife pierced his chest. Family members carried Gerry to the hospital where he was declared dead.
The prosecution relied on testimony of Cristina’s daughter, Christine, who testified that as the quarrel escalated Cristina retrieved a knife inserted on the roof and stabbed Gerry. The prosecution also noted that Cristina fled and evaded arrest for four years.
The Regional Trial Court (RTC), Branch 65, Tarlac City, found Cristina guilty in its September 27, 2012 Decision, ruling that unlawful aggression had ceased when Gerry was disarmed and that Cristina had provoked the fatal encounter; it sentenced her to reclusion perpetua and awarded civil damages. The Court of Appeals (CA) in CA‑G.R. CR HC No. 05832 affirmed the RTC in its May 6, 2014 Decision, taking Cristina’s flight as undermining her cla...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in rejecting the plea of self‑defense and in affirming the conviction of Cristina Samson for parrici...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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