Case Summary (G.R. No. 196264)
Extrajudicial Confession and Guilty Plea
On March 5, 1945, before the Justice of the Peace, appellant executed Exhibit C—an affidavit in which he confessed that shame at alleged threats from his uncle drove him to kill his wife with scissors, then his son, and then to wound himself. Exhibit D records his plea of guilty at the arraignment. Sgt. Pimentel corroborated that appellant admitted wishing to kill his family out of shame.
Voluntariness and Admissibility of Confession
The Justice of the Peace and Sgt. Pimentel testified that Exhibit C was read to appellant, who understood and signed it voluntarily without coercion. Allegations that Pimentel threatened to shoot appellant were rejected as implausible and unsupported. The court found no violation of due process under the 1935 Constitution.
Spousal Testimony and Rebuttal Exception
Defense counsel invoked Rule 123(26)(d) to bar wife’s testimony against her husband. The majority held that, by testifying in his own defense that his wife caused the child’s death, appellant introduced new matter, thereby waiving spousal privilege and permitting rebuttal under Rule 115(3)(c). A dissent argued that no statutory exception supports compelling a wife to testify against her husband in such circumstances and that her testimony should have been excluded.
Criminal Liability and Mitigating Circumstance
The Supreme Court found parricide proved beyond reasonable doubt by appellant’s confession and consistent evidence. No insanity or total lack of volition was established, but
...continue readingCase Syllabus (G.R. No. 196264)
Procedural Posture
- Defendant Juan Francisco was convicted of parricide by the Court of First Instance of Mindoro.
- He appealed to the Supreme Court asking for reversal and acquittal.
- The Supreme Court received briefs, heard testimony, and reviewed documentary exhibits, including Exhibit C (extrajudicial confession) and Exhibit D (arraignment record).
Facts of the Case
- On March 4, 1945, Francisco, detained for robbery, was in the municipal jail of Mansalay, Mindoro.
- He obtained permission from Chief of Police Alfredo Iwahi to go home with Sergeant Pacifico Pimentel to arrange bail.
- At the family house, Pimentel remained at the foot of the stairs while Francisco talked to his wife in an upstairs room.
- A woman’s scream was heard; Francisco’s wife emerged wounded in the right breast, bleeding.
- Francisco lay on a bed with his one-and-a-half-year-old son Romeo on his chest; Francisco had an abdominal wound, the child a fatal back wound.
- Sergeant Pimentel’s timely intervention prevented further violence; the child was dead on discovery.
The Extrajudicial Confession (Exhibit C)
- Dated March 5, 1945, sworn before the Justice of the Peace of Mansalay.
- Defendant admitted:
• Requesting permission to raise his bail bond and identify a surety’s house.
• Accompanying Pimentel to his home; Pimentel waited downstairs.
• A flash of memory about an uncle’s threat against him, prompting suicidal and homicidal impulses.
• Seeing a pair of scissors beside his wife, unconsciously stabbing her, then stabbing his son, and finally inflicting a wound upon himself.
• Hearing a gunshot, followed by Pimentel’s order to surrender, to which he assented before losing consciousness.
Testimony of Sergeant Pacifico Pimentel
- Credibility of Pimentel was upheld by the Court.
- He related that Francisco confessed murder of wife, child, and intention to kill himself due to shame from an accusation by his father-in-law.
- Pimentel denied using force, threats, or mistreatment to obtain any statement.
- He corroborated that no coercion occurred during or after the incident.
Voluntariness and Spontaneity of Confession
- The Justice of the Peace, Pimentel, Sebastian Punzalan, and Chief Iwahi witnessed Exhibit C’s execution.
- The Justice of the Peace testified:
• He read the contents aloud; defendant affirmed understanding.
• No intimidation or violence was used, and Francisco signed voluntarily. - Pimentel testified: • No threats or force exerted; the affidavit was read to defendant, who then signed of his own free will.
Contradictions and Credibility of the Accused
- Defendant’s own testimony contained inconsistencies:
• He alternately claimed Pimentel stayed behind and that Pimentel accompanied him upstairs.
• He alleged threats of s