Title
People vs. Abarca
Case
G.R. No. 74433
Decision Date
Sep 14, 1987
A man, discovering his wife's infidelity, killed her lover in a fit of passion, injuring bystanders; court applied Article 247, reducing charges.
A

Case Summary (G.R. No. L-23827)

Procedural History

The accused was charged by amended information with the complex crime of murder with double frustrated murder. He pleaded not guilty at arraignment. The Regional Trial Court (RTC) of Palo, Leyte convicted him of murder with double frustrated murder and imposed the death penalty, plus indemnities. Because the RTC imposed death, the case was elevated to the Supreme Court. In light of the approval of the new Constitution abolishing the death penalty and commuting existing death sentences, the Court required the accused to indicate whether he wished to pursue the appeal; he elected to proceed.

Facts Found by the Trial Court and Prosecution Narrative

While the accused was in Manila for bar exam review, his wife allegedly began an illicit relationship with Koh. On July 15, 1984, the accused discovered his wife and Koh in the act of sexual intercourse at his residence. After leaving briefly, he obtained an M-16 rifle from PC soldier Arturo Talbo, returned to Tacloban, went to the mahjong session where Koh was playing, and fired three shots at Koh. Koh died instantly from multiple gunshot wounds. Arnold and Lina Amparado, occupying an adjacent room, were struck and wounded. Arnold incurred significant medical expenses and temporary incapacity; Lina also required hospitalization.

Issues Presented on Appeal

The accused-appellant raised two principal assignments of error: (I) that the RTC erred in convicting him of murder instead of applying Article 247 of the Revised Penal Code (death inflicted under exceptional circumstances), and (II) that the RTC erred in finding the killing was attended by treachery. The Solicitor General recommended applying Article 247 and, to the extent the injuries to the Amparados constituted a separate offense, to convict for double frustrated murder and impose the appropriate penalties under Article 48 (complex crime rules).

Legal Character and Purpose of Article 247

The Court analyzed Article 247 and reaffirmed established precedents that Article 247 does not define a separate substantive crime. Rather, it is an exceptional circumstance that operates as a privilege or exemption that substantially reduces the legal consequences of acts that, absent the provision, would constitute homicide, murder, parricide or serious physical injury. When the provision’s conditions are satisfied and death or serious physical injury results, the statutory penalty is destierro (banishment); for physical injuries other than serious, the offender may be exempt from punishment. As such, Article 247 functions as an exempting or mitigating rule, not as an independent offense whose elements must be pleaded by the prosecution.

Application of Article 247 to the Facts

The Court concluded that the statutory prerequisites of Article 247 were satisfied: the accused was a legally married person who surprised his spouse engaged in sexual intercourse with another (Koh) and thereafter killed the other person. The lapse of time between discovery and the killing (approximately one hour) did not preclude application of Article 247; the Court explained that the statute requires the killing to be in the act or immediately thereafter but does not demand instantaneous action. The essential test is whether the killing was the proximate result of the outrage and the same blind impulse caused by the discovered infidelity, not whether there was a brief interval. Because the killing was directly traceable to the accused’s outraged passion upon discovering the adultery, Article 247 applied.

Effect of Applying Article 247 on Criminal Liability and Aggravating Circumstances

Because Article 247 is an exempting privilege rather than a crime, the act of “inflicting death under exceptional circumstances” is not punishable in the ordinary sense and therefore cannot be further qualified by aggravating circumstances such as treachery. The Supreme Court held that treachery could not be appreciated to elevate or alter the legal characterization once Article 247’s exceptional circumstances were found to be operative. Consequently, the RTC erred in convicting the accused of murder with treachery.

Liability for Injuries to Third Parties (Arnold and Lina Amparado)

The Solicitor General’s recommendation to treat the wounds to the Amparados as frustrated murders was rejected. The Court reasoned that Article 247 removed the criminal character of the primary act (killing under exceptional circumstances) such that the accused was not committing a punishable felony at the time he fired. Since the rule that an offender is criminally liable for all consequences of his act presupposes that the act itself is a felony, that rule did not automatically extend to impose frustrated murder liability for the bystanders’ injuries in this context.

Nevertheless, the Court found the accused culpable for negligence. Although the accused uttered a warning ("those not concerned, get out") before firing, this did not suffice to absolve him of responsibility for negligently wounding bystanders. The Court applied the provisions governing liability for physical injuries caused by simple imprudence or negligence (Article 365, first part, second paragraph) and found that the Amparados suffered less serious physical injuries through the accused’s imprudence.

Penalty Determination and Indemnity

Given the characterization under Article 247 with respect to Koh and the separate negligence liability for the Amparados, the Supreme Court modified the RTC judgment. The Court sentenced the accused for the injuries of the Amparados to arresto mayor (in its medium and maximum periods), concretely fixing the penalty at four months and 21 days to six months. The period already served in confinement was to be credited toward this penalty. The accused was ordered to indemnify Arnold and Lina Amparado P16,000 for hospitalization expenses and P1,500

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