People vs. Ulep

G.R. No. L-36858
Husband convicted of parricide after admitting to elbowing wife, causing fatal injuries; autopsy confirmed fresh fractures, leading to cardiac arrest.
parricide conviction cardiac arrest

Case Digest (G.R. No. L-36858)

Facts:

People of the Philippines v. Macario A. Ulep, G.R. No. L-36858, June 20, 1988, Supreme Court First Division, Gancayco, J., writing for the Court. The plaintiff-appellee was the People of the Philippines; the accused-appellant was Macario A. Ulep.

On May 21, 1970, Asuncion Pablo Ulep (the victim) was found dead in San Nicolas, Ilocos Norte. The Chief of Police and the Rural Health Officer visited the house the next day; the husband initially refused permission for an autopsy. At the behest of the victim’s daughter, however, Dr. Eliseo V. Bonoan (prosecution medical witness) and the police intercepted the funeral procession at the cemetery and performed a post-mortem on May 25, 1970. The necropsy disclosed multiple complete rib fractures (left 4th–7th; right 3rd–4th), pleural lacerations, about 200 cc serous pleural fluid, 500 cc serous abdominal fluid, congested meningeal vessels and small clotted blood in the heart; the stated cause of death was “cardiac arrest primary shock.”

Two constabulary sergeants later investigated and took two sworn statements by the accused (Exhibits “A” and “B”) in which he admitted elbowing his wife and causing her death. In court he retracted these admissions, testifying instead that more than a year earlier the wife had been pinned by a bullcart and treated by an arbularyo, and that prior trauma might explain the rib fractures and her eventual death.

The Court of First Instance of Ilocos Norte, Second Judicial District convicted Ulep of parricide, sentenced him to reclusion perpetua, ordered indemnity of P12,000 to the heirs, and imposed costs (Decision dated March 20, 1973). The accused appealed to the Supreme Court, challenging the trial court’s findings on the cause of death and arguing ...(Pro-only)

Issues:

  • Was the cause of Asuncion Pablo’s death cardiac arrest and primary shock resulting from rib fractures inflicted by the accused’s elbow blows?
  • Did a pre-existing, long-standing medical condition or prior injury (as the accused alleged) sufficiently explain the rib fractures and cardiac arrest so as to negate criminal liability?
  • Should the conviction for parricide and the penalties imposed by the t...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)
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