G.R. No. 102984 - People vs. Takbobo

The case involves the People of the Philippines, as plaintiff-appellee, and Ruben Takbobo, the accused-appellant.
Ruben Takbobo, a middle-aged fisherman, was married to Lucia Takbobo in 1969.
The couple had nine children, though one was already dead, and some of the children lived separately due to a fear of their father.

On March 25, 1991, at approximately 11:00 P.M. in Barangay Guiwanon, Ginatilan, Cebu, Ruben Takbobo allegedly hacked and stabbed his wife with a knife and a bolo.
Multiple fatal wounds were inflicted on Lucia Takbobo, which resulted in her instantaneous death.
The incident was witnessed by their youngest daughter, 6-year-old Madilyn, who provided detailed testimony regarding the quarrel between her parents and the subsequent stabbing.

Recounted waking up due to a noisy quarrel and witnessing her father attacking her mother.
Described the wounds inflicted on various parts of her mother's body.

Appellant’s own investigation with the police, including his statements during the custodial investigation by Pfc. Alfredo Cavalina and corroborative proximity of Policeman Reynaldo Singco.
Photographic evidence (Exhibits “A” to “D”) depicting the victim’s physical condition, which in part contradicted some of the defense’s claims.
Prior instances of violence involving Takbobo against his own children, as testified by his 16-year-old daughter, Irene.

Takbobo claimed that he killed his wife after discovering her in an adulterous act with Cadiz Catulong, a neighbor.
His account included details such as:

Arriving home at about 3:00 A.M. from a fishing activity.
Observing his wife engaged in a sexual act, his attempted intervention, and his subsequent claim that she was accidentally killed when she pushed the other man.
Noting that his wife was not wearing panties—a detail later contradicted by some photographic evidence.

Despite pleading guilty at arraignment, the lower court required further evidence to explore the motive and circumstances.
On October 14, 1991, the trial court rendered judgment finding the accused guilty of parricide.
The penalty imposed was reclusion perpetua along with an order to indemnify the heirs of the deceased and pay court costs.

Whether the accused’s claim of having acted under a state of passion, obfuscation, and with the mitigating circumstances of voluntary surrender and pleading guilty, should have resulted in the reduction of his penalty.
Whether the alleged discovery of his wife in the act of adultery—with the attendant specific mitigating circumstance under Article 247 of the Revised Penal Code—was proven by clear and convincing evidence.
The proper interpretation and application of the rules on the imposition of penalties, particularly:

The distinction between divisible and indivisible penalties as provided under Articles 63 and 64 of the Revised Penal Code.
Whether the reduction of the penalty by one degree (from reclusion perpetua to reclusion temporal) was legally justified given the presence of mitigating circumstances.