G.R. No. 128845 - International School Alliance of Educators vs. Quisumbing

The accused, George Zapata y Viana, was charged with the crime of parricide under Art. 246 of the Revised Penal Code as amended by R.A. 7659.
The Information alleged that on or about May 11, 2002, in Rodriguez, Rizal, while armed with a .45 caliber pistol, the accused intentionally, with treachery and evident premeditation, attacked and shot his wife, Queeny Zapata y Erespe, inflicting a gunshot wound to her left chest that led to her death.
The criminal complaint detailed that the shooting occurred during nighttime and was committed while the accused was observed to be under the influence after a drinking session with relatives.

Earlier on May 11, 2002, at around 3:00 p.m., the accused was seen engaging in a drinking spree with his brother Manny Zapata and cousin Edwin Bautista at their family home in Kasiglahan Village, San Jose, Rodriguez, Rizal.
At approximately 7:00 p.m., a gunshot was heard emanating from the bedroom where the accused and his wife were together.
Evidence showed that a single close-range gunshot was fired, entering Queeny’s left chest and exiting through her left lumbar region, with forensic details revealing injuries to the epigastric region, fractures of the sternum at the level of the 6th interior ribs, and damage to internal organs such as the liver, pancreas, and left kidney.

Neighbors were alerted by the sound of the gunshot.
The empty shell of the .45 caliber pistol was recovered from the scene by SPO1 Onofre C. Tavas.
Testimony by a medico-legal officer described the bullet trajectory and wound details, indicating the shot was fired at a distance of three to four inches.

After firing the shot, the accused brought his bloodied wife’s body to the sala.
Instead of immediately seeking help, he fled from the scene, leaving his wife unattended and alone on a chair, despite her being in critical condition.

Queeny’s body was later brought to the Amang Rodriguez Medical Center, and their three-year-old daughter Angel was taken to the Municipal Hall of San Mateo, Rizal by a friend and neighbor.
No relative of the accused volunteered to assist in transporting the victim to the hospital immediately.

He maintained that he attempted to show the gun to his cousin, and while retrieving it from a cabinet, the gun fell causing an involuntary discharge that struck his wife.
This narrative was inconsistent with the usual reflex when catching a falling object, as instinctively one would use both hands, making it highly unlikely that a trigger was accidentally squeezed.

The trajectory of the bullet evidenced that the shot came from the front of the victim, rather than from the falling gun from the floor.
Detailed autopsy findings confirmed a purposeful shot rather than an accidental one, given the wound’s path and associated injuries.

At trial, the accused pleaded not guilty, but the Regional Trial Court found him guilty beyond reasonable doubt, sentencing him to reclusion perpetua and ordering the payment of actual, moral, and death indemnity damages.
On appeal, the Court of Appeals upheld the conviction and modified the awards by increasing the civil indemnity and exemplary damages.
The appellate decision was rendered with detailed observations that challenged the accidental discharge claim, focusing on the accused’s handling of the weapon and his conduct following the shooting.

Whether the evidence and circumstances support the accused’s contention that the shooting of his wife was accidental.
Whether the explanation provided regarding the trigger being unintentionally squeezed while retrieving a falling gun is credible and consistent with human reflexes.

Whether the facts sufficiently demonstrate that the accused intentionally shot his wife.
Whether the multiple safety measures of the firearm—and the accused’s failure to observe these precautions—indicate a deliberate act rather than an accident.

Evaluating if the accused’s behavior after the shooting (leaving his wife unattended and fleeing the scene) is congruent with an accidental discharge scenario.
Whether his actions immediately following the incident undermine his claim of lacking criminal intent.

Whether all required elements of parricide, namely the death of the victim, the direct causation by the accused, and the intimate relation of the victim (spouse), have been legally and factually established.
The relevance of precedents, such as People v. Castillo, in solidifying the mens rea and actus reus in this case.