Case Digest (G.R. No. 14170)
Facts:
- In "People vs. Merced" (G.R. No. 14170), decided on November 23, 1918, Catalino Merced and Apolonia Patron were charged with homicide.
- The incident occurred on March 4, 1918, in Palimpinon, Luzuriaga.
- Merced had supper at Teodora Sarasin's house, joined by Patron who brought cooked rice.
- After supper, Merced and Patron rested in Sarasin's main room.
- Sarasin was awakened by a struggle and heard Patron tell her husband, Pantaleon Arabe, that she was wounded, to which Arabe replied, "That is what you got."
- Sarasin fled but returned to find Arabe bloody on the floor.
- Arabe's body was later found on the riverbank near his house.
- Filomena Ago testified that Patron had shown her a dagger (Exhibit B) and complained about her husband's suspicions of an affair with Merced.
- The health officer confirmed Arabe died from a wound inflicted by a double-edged dagger.
- Merced claimed self-defense, stating Arabe attacked him with a bolo, and he fatally wounded Arabe with the dagger.
- Patron did not testify.
- The Court of First Instance sentenced Merced to fourteen years, eight months, and one day of reclusion temporal, and Patron to eight years and one day of prision mayor, with indemnity payments to Arabe's heirs.
- Both defendants appealed the decision.
Issue:
- (Unlock)
Ruling:
- Yes, the crime committed was homicide.
- No, Catalino Merced did not act in self-defense.
- No, there was insufficient evide...(Unlock)
Ratio:
- The Court held that the facts constituted homicide under Article 404 of the Penal Code, with no qualifying circumstance to elevate it to murder.
- The Court found no evidence to support Merced's claim of self-defense. Even if Arabe had attacked Merced, it would have been a natural and lawful defense of his honor as an offended husband.
- Merced, by maintaining illicit relations with a married woman, exposed himself to the risk of being attacked by her husband.
- Regarding Apolonia Patron, the Court found no conclusive proof that she coop...continue reading
Case Digest (G.R. No. 14170)
Facts:
In the case "People vs. Merced" (G.R. No. 14170), decided on November 23, 1918, by the Philippine Supreme Court, the defendants Catalino Merced and Apolonia Patron were charged with the crime of homicide. The incident took place on the night of March 4, 1918, in the barrio of Palimpinon, Luzuriaga. Catalino Merced went to the house of Teodora Sarasin, where he had supper with her and later with Apolonia Patron, who brought cooked rice from her nearby house. After supper, both Merced and Patron went to rest in the main room of Sarasin's house. During the night, Sarasin was awakened by a struggle in the room and heard Apolonia tell her husband, Pantaleon Arabe, that she was wounded, to which Arabe replied, "That is what you got." Out of fear, Sarasin left the house but returned shortly to find Arabe lying bloody on the floor. The justice of the peace later found Arabe's body on the riverbank near his house.
Filomena Ago, Merced's sister-in-law, testified that two days before the crime, Patron had complained about her husband suspecting her of having an affair with Merced. Patron had shown Ago a dagger (Exhibit B) during their conversation. The health officer confirmed that Arabe died from a serious wound inflicted by a double-edged dagger. Merced claimed self-defense, stating that Arabe attacked him with a bolo...