G.R. No. L-44063 - Corales vs. Employees' Compensation Commission

Procedural History
Complaint filed by the prosecuting attorney on August 1, 1914, charging Eufrasio Alano y Agbuya with homicide.
Trial court rendered judgment on October 19, 1914, sentencing defendant to fourteen years, eight months, and one day of cadena temporal, accessory penalties, and costs.
Defendant appealed the conviction to the Supreme Court.

Background Antecedents
Eufrasio Alano and Teresa Marcelo married and lived in Malate with the deceased’s mother, Maria Remigio, and other relatives. Alano had an unblemished record as a domestic servant.
Beginning in March 1913, Teresa Marcelo engaged in illicit relations with neighbor Martín Gonzalez:

She disappeared with her mother to Corregidor, returning in July 1913 visibly pregnant; delivered a child in December 1913.
The baptism in December 1913 was celebrated at Modesta Carballo’s store, where Marcelo and Gonzalez frequently met.

Husband’s observations of recurring familiarity: early‐morning window encounters, gambling sessions in the marital home, and meetings at the Chinese store on Calles Tennessee and Dakota.
During a three‐month stay in Baguio (March–June 1914), Alano received and re-sent to his wife a letter exposing her infidelity. Upon return, he caught the pair in bed in June 1914, pardoned her on promise of fidelity, then purchased a fan-knife and warned her against repetition.

Events of July 27, 1914
About 5:00 p.m., Modesta Carballo gave Teresa Marcelo five cinematograph tickets; most household members went to the show while Marcelo stayed home to care for a sick child. Alano and Marcelo played blackjack; Marcelo later left to visit a nearby Chinese store.
Failing to find her there, Alano searched an alley, stumbled over a wire, and discovered Marcelo in the act of intercourse with González among bamboo grass. He drew his fan-knife and pursued González—who escaped—then returned home.
At the house, Alano found Marcelo on the stairs, reprimanded her, and stabbed her repeatedly as she tried to flee. She fell twice—once inside near Ricarda Garces and again outside by a stair post—and died shortly thereafter.
Autopsy revealed twenty-four stab wounds, including a severed jugular vein and a broken knife point embedded in her head. Photographs and sketches of the crime scene and corpse are in the record. Prosecution witnesses were largely absent at key moments; the sole in-house witness saw only Marcelo’s entry. Alano’s detailed confession remained uncontradicted.

Whether the killing is ordinary homicide or the special homicide under Article 423 of the Penal Code for killing upon catching one’s spouse in adultery.
Whether the defendant’s confession must be admitted in its entirety, including extenuating circumstances of prior and immediate provocation.
Whether the prosecution’s witnesses had the opportunity and credibility to contradict the defendant’s account.