Case Summary (G.R. No. 110120)
Petitioner
Manolito Oyanib y Mendoza, convicted of homicide (Crim. Case No. II-6012) and parricide (Crim. Case No. II-6018) by the Regional Trial Court of Iligan City
Respondent
People of the Philippines
Key Dates
– Offenses committed: September 4, 1995
– Informations filed and surrender: September 11, 1995
– Arraignment: January 17, 1996
– Trial court decision: May 26, 1997
– Notice of appeal filed: June 17, 1997
– Supreme Court decision: March 12, 2001
Applicable Law
– Revised Penal Code (Articles 246, 247, 248 on parricide, exceptional circumstances privilege, and homicide)
– Republic Act No. 7659 (imposing reclusion perpetua for parricide)
– Indeterminate Sentence Law
– 1987 Philippine Constitution
Factual Background
Manolito and Tita married in 1979 and separated in 1994; Manolito retained custody of their two children. Tita moved to a second-floor rented room at Edgardo Lladas’s house in Iligan City. On the evening of September 4, 1995, Manolito approached Tita’s rented room to request her attendance at a school meeting concerning their son. He heard sounds of sexual activity, pried open the door with a hunting knife, and discovered Tita and Jesus Esquierdo in flagrante delicto. A physical altercation ensued: Jesus kicked Manolito, who then stabbed Jesus multiple times. Tita attacked Manolito with a broken bottle, prompting Manolito to stab her repeatedly. Tita died en route to the hospital; Jesus died at the scene. Manolito fled but surrendered the next day upon public broadcast.
Procedural History
The Iligan City Prosecutor filed separate informations charging Manolito with:
- Murder of Jesus Esquierdo under Article 248, aggravated by evident premeditation (Crim. Case No. II-6012)
- Parricide of Tita Oyanib under Article 246 (Crim. Case No. II-6018)
The trial court conducted a joint trial. On May 26, 1997, it found Manolito guilty beyond reasonable doubt, applying two mitigating circumstances (passion or obfuscation and voluntary surrender) and imposing:
– Homicide: six months–six years and one day–eight years of imprisonment (indeterminate), P50,000 civil indemnity
– Parricide: reclusion perpetua, P50,000 civil indemnity
Manolito appealed, invoking Article 247 (exceptional circumstances privilege) and contesting the trial court’s factual findings.
Issue
Whether Manolito satisfied the requirements of the exceptional‐circumstances privilege under Article 247 of the Revised Penal Code, which would relieve him of criminal liability for killing his wife and her paramour upon surprising them in the act of sexual intercourse.
Legal Analysis
Article 247 provides an exempting circumstance where a legally married spouse kills the unfaithful spouse (and paramour) during or immediately after catching them in flagrante delicto, provided the offended spouse did not consent to the infidelity nor facilitate it. The accused bears the burden of proving, by clear and convincing evidence, that:
- He surprised his spouse committing sexual intercourse with another
- The killing occurred in the act or immediately thereafter
- He did not condone or facilitate his spouse’s infidelity
The Court found all three elements satisfied:
– Manolito indisputably chanced upon Tita and Jesus in the act.
– He stabbed th
Case Syllabus (G.R. No. 110120)
Facts of the Case
- Manolito Oyanib y Mendoza and Tita T. Oyanib married on February 3, 1979; they had two children, Desilor and Julius.
- In 1994, the spouses separated due to marital differences; Manolito retained custody of the children; Tita rented a room on the second floor of Edgardo Lladas’s house in Tambacan, Iligan City.
- Tita openly maintained a relationship with Jesus Esquierdo, whom she allegedly flaunted in front of Manolito.
- On the evening of September 4, 1995, Manolito, having learned from a school letter that Tita was invited to a meeting about their son’s failing grades, went to her rented room to fetch her to the meeting.
- He heard sounds from inside, forced the door open with a hunting knife, and found Tita and Jesus in flagrante delicto.
- Jesus kicked Manolito; Manolito stabbed Jesus repeatedly, causing him to fall; Tita struck Manolito with a broken Tanduay bottle; Manolito then stabbed Tita multiple times.
- Edgardo Lladas appeared, Manolito told him not to interfere, then left; Tita and Jesus were mortally wounded—Tita died en route to the hospital, Jesus died at the scene.
- Manolito discarded the knife, fled to nearby towns, heard broadcast urging him to surrender, and turned himself in to the police early on September 5, 1995.
Procedural History
- On September 11, 1995, the Iligan City Prosecutor filed two separate informations:
• Criminal Case No. II-6012 charging murder of Jesus Esquierdo under Article 248, RPC, with evident premeditation.
• Criminal Case No. II-6018 charging parricide of Tita Oyanib under Article 246, RPC, with evident premeditation. - The prosecutor recommended no bail; Manolito voluntarily surrendered and was detained.
- On January 17, 1996, Manolito was arraigned, the informations were read and translated into Visayan, and he pleaded not guilty to both charges.
- Because both cases arose from the same facts, the trial court conducted a joint trial, receiving testimony from Edgardo Lladas, SPO3 Eduard Tubil, Dr. Leonardo A. Lab