Title
People vs. Oyanib y Mendoza
Case
G.R. No. 130634-35
Decision Date
Mar 12, 2001
Manolito, upon catching his wife and paramour in adultery, killed them in a fit of passion. The Supreme Court ruled his actions justified under Article 247, sentencing him to destierro.

Case Summary (G.R. No. 130634-35)

Chronology of criminal proceedings and appeal

September 4, 1995: killings occurred.
September 11, 1995: two informations filed (Criminal Case No. II‑6012 for murder of Jesus; Criminal Case No. II‑6018 for parricide of Tita); accused surrendered same day and detained.
January 17, 1996: arraignment; accused pleaded not guilty; joint trial conducted.
May 26, 1997: Regional Trial Court (RTC), Branch 02, Iligan City, rendered a joint decision finding accused guilty of homicide and parricide and imposed indeterminate and reclusion perpetua sentences plus civil indemnities.
June 17, 1997: accused appealed to the Supreme Court. March 12, 2001: Supreme Court decision reversing the RTC and imposing destierro (two years and four months) with restricted area.

Factual Summary

Core events established at trial

Manolito and Tita were married since 1979 and separated in 1994, with Manolito having custody of their two children. Tita rented the second floor of Edgardo Lladas’s house. On the evening of September 4, 1995, Manolito went to Tita’s rented room to ask her to attend a school meeting for their son. Upon entry he surprised Tita and Jesus in the act of sexual intercourse. A commotion ensued: Jesus kicked Manolito, there were mutual and successive stabbings (Manolito stabbed Jesus multiple times; Tita struck and stabbed Manolito with a broken bottle and was then stabbed by Manolito multiple times). Neighbors brought Tita to the hospital but she died en route; Jesus was found dead at the scene with multiple stab wounds. Edgardo saw the events unfolding and called the police. Manolito left the scene, disposed of the knife, stayed elsewhere briefly, then surrendered to police after a public call for him to do so. Medico-legal examinations established multiple fatal stab wounds for both victims and causes of death consistent with the stabbings.

Charges and RTC Disposition

Initial criminal charges and trial court findings

Two informations charged (1) murder of Jesus under Article 248, R.P.C. (with evident premeditation alleged) and (2) parricide of Tita under Article 246, R.P.C. The prosecutor recommended no bail. The RTC conducted a joint trial, found Manolito guilty beyond reasonable doubt of homicide (Crim. Case No. II‑6012) and parricide (Crim. Case No. II‑6018), applied mitigating circumstances (passion/obfuscation and voluntary surrender), and imposed a flawed indeterminate penalty for homicide and reclusion perpetua for parricide, plus civil indemnities. The RTC’s imposition of indeterminate terms was noted to be incorrect in form (the judge set indefinite minimum and maximum periods without applying the Indeterminate Sentence Law correctly).

Issue on Appeal

Central legal question presented to the Supreme Court

Whether accused Manolito satisfied the stringent requirements of Article 247, Revised Penal Code (the absolution/exempting privilege for a legally married person who surprises his spouse in the act of sexual intercourse and kills any of them in the act or immediately thereafter), thereby justifying relief from criminal liability or a lighter sanction.

Legal Framework

Article 247 R.P.C., burden of proof, and controlling precedent

Article 247, R.P.C., provides an exempting cause when: (1) a legally married person surprises his spouse in the act of sexual intercourse with another; (2) he kills any of them or both in the act or immediately thereafter; and (3) he neither promoted nor consented to the spouse’s prostitution or infidelity. The accused bears the burden to prove these elements by clear and convincing evidence. The rulings cited include People v. Talisic and People v. Wagas, which emphasize that the killing must be the proximate result of immediate outrage upon catching the spouse flagrante delicto and that the law imposes stringent temporal and factual requirements.

Application of Law to Facts

Supreme Court’s factual and legal assessment supporting Article 247

The Supreme Court accepted that the first element was satisfied: Manolito surprised his wife and Jesus in the act of sexual intercourse. It then focused on whether the killings occurred “in the act or immediately thereafter” and whether the reaction was the proximate result of the outrage. After reviewing testimonial and physical evidence (including eyewitness account by Edgardo and scene findings), the Court concluded that Manolito acted within the exceptional circumstances contemplated by Article 247. The factual narrative showed that Manolito was suddenly confronted with his wife and her paramour in flagrante delicto, Jesus physically assaulted/kicked him, the subsequent struggle led to stabbing of Jesus, and Tita’s aggressive conduct (hitting with a bottle, stabbing Manolito in the arm, and shouting in support of Jesus) contributed to the immediate outrage culminating in the deadly stabbings. The Supreme Court found these circumstances sufficient to satisfy the requirement that the killing concur with the flagrante delicto and to establish the proximate causation by the passionate outrage.

Evidence and Burden Considerations

Burden of proof, contested evidence, and Court’s credibility determinations

Although the accused argued that physical exhibits (a photograph showing Jesus’ pants allegedly unfastened) supported his claim of flagrante delicto, the Solicitor General contended the accused failed to meet the clear-and-convincing standard. The Supreme Court resolved credibility and evidentiary questions in favor of the accused’s claim that he chanced upon the act and was driven to immediate outrage by what he witnessed and by subsequent violent resistance and threats. The Court emphasized the strictness of Article 247’s requirements but concluded that, on the record, those requirements were met.

Supreme Court Holding and Sentence

Reversal, substituted penal outcome, and restrictions imposed

The Supreme Court reversed the RTC’s conviction and penal disposition for homicide and parricide insofar as those convictions imposed ordinary penal liabilities. Instead, the Court treated the killings as falling within Article 247’s exempting circumstances and imposed, as the operative sanction, destierro for two years and four months. The Court also prohibited Manolito from entering Iligan City or within a radius of 100 kil

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