G.R. No. 214883 - People vs. Samson

On August 14, 2002, Cristina Samson (appellant) was charged with parricide under Article 246 of the Revised Penal Code for stabbing and killing her husband, Gerry Delmar, on June 27, 2002, in Tarlac City.
The Information alleged that Cristina willfully and feloniously stabbed her husband in the chest with a knife, resulting in his death.
Cristina pleaded not guilty almost four years later at arraignment.

The parties agreed to a reverse trial since Cristina invoked the justifying circumstance of self-defense.

On June 27, 2002, Cristina was at home with her children watching television when her drunk husband, Gerry, arrived and demanded food.
She lacked money and had not cooked food, which started a quarrel where Gerry scolded and slapped Cristina.
After a brief pacification by Cristina's father, Gerry left but returned 30 minutes later, pointing a knife at Cristina’s neck.
Cristina begged for mercy, but Gerry threatened to stab her. He slapped her twice more.
Cristina pushed Gerry, causing him to fall; she took the knife from him and warned him not to come near.
While holding the knife near her chest, Gerry suddenly grabbed her, and the knife stabbed him in the chest.
She shouted for help; her father and brother brought Gerry to the hospital where he died.

Gerry and Cristina were married since 1994, had two daughters, and lived in a house adjacent to Cristina’s family.
Their relationship was marked by constant quarrels before the fatal incident.
On June 27, 2002, Gerry came home drunk and quarreled with Cristina over dinner, and Christine (daughter) witnessed the fight.
During the fight, Cristina got hold of a knife from the roof and stabbed Gerry, who crawled out of the house.
Cristina left after asking her father for money, and Gerry died later in the hospital.

The RTC found Cristina guilty beyond reasonable doubt of parricide and sentenced her to reclusion perpetua.
The RTC held that the self-defense plea was untenable as Gerry’s unlawful aggression ceased when he put down the knife.
It found Cristina provoked Gerry by pushing him after he dropped the weapon, and that stabbing him was unjustified.
Cristina was ordered to pay civil, moral, and exemplary damages.

The CA affirmed the RTC decision, agreeing that unlawful aggression ceased when Gerry disarmed himself.
It noted Cristina’s four-year flight and evasion of arrest as contrary to her claim of innocence.

Whether the Court of Appeals erred in not appreciating the justifying circumstance of self-defense invoked by Cristina Samson.