Case Summary (G.R. No. 179035)
Petitioner
Jesus Paycana Jr.
Respondent
The People of the Philippines
Key Dates
• November 26, 2002 – Date of stabbing incident
• January–June 2004 – Trial-level testimonies and proceedings
• April 14, 2005 – RTC decision convicting appellant
• May 30, 2007 – Court of Appeals affirmation (modified penalty)
• June 14, 2007 – Notice of appeal filed with Court of Appeals
• April 16, 2008 – Supreme Court promulgation
Applicable Law
• 1987 Philippine Constitution
• Revised Penal Code:
– Article 11 (Justifying circumstances: self-defense)
– Article 246 (Parricide)
– Article 257 (Unintentional abortion)
– Article 48 (Complex crimes)
• Republic Act No. 9346 (Abolition of death penalty)
• Rules of Criminal Procedure (Rule 122 on automatic appeals in death penalty cases)
• Civil Code provisions on indemnity and damages
Facts
- Appellant admitted during pre-trial that Lilybeth was his legitimate spouse.
- On the morning of November 26, 2002, appellant returned from work armed with a kitchen knife and a bolo. Lilybeth was preparing their children for school.
- For reasons undisclosed, appellant stabbed his wife fourteen times, causing her immediate death and termination of the seven-month fetus.
- Angelina witnessed the attack through a window, saw her father strangle and stab her mother, and cried for him to stop.
- Tito heard Lilybeth’s screams, arrived at the scene, saw her prostrate and trembling, and observed appellant armed and standing over the victim.
- Appellant claimed self-defense, alleging that Lilybeth attacked him first with the knife, that he wrested it from her, and then stabbed her in return; he professed not to recall the exact number of wounds due to dizziness and bleeding.
Issue
Whether the evidence and circumstances warranted recognition of the justifying circumstance of self-defense in appellant’s favor.
Trial Court Ruling
The RTC found appellant guilty beyond reasonable doubt of the complex crime of parricide with unintentional abortion. It imposed the maximum penalty of death (later commuted to reclusion perpetua) and awarded civil indemnity (₱50,000), moral damages (₱50,000), and exemplary damages (₱25,000) to the heirs of Lilybeth.
Court of Appeals Ruling
Affirmed the RTC’s conviction but modified the penalty from death to reclusion perpetua pursuant to RA 9346. It held that appellant failed to prove self-defense by clear and convincing evidence and that eyewitness and medical testimony negated any lawful aggression by the victim.
Supreme Court Analysis
- Self-defense is a purely factual matter, with the burden of proof on the accused to establish:
a. Unlawful aggression by the victim;
b. Reasonable necessity of the means employed; and
c. Absence of sufficient provocation by the defender (RPC Art. 11). - Eyewitness testimony of Angelina (age 15), corroborated by Tito and medical findings, established that appellant was the initial aggressor. His account of being stabbed first was undermined by:
• Inconsistent testimony regarding the number and nature of his wounds (a defense witness conceded they could be self-inflicted superficial cuts).
• Physical evidence of fourteen stab wounds indicating a deliberate killing rather than a defensive reaction. - Unlawful aggression by the victim was not proven. Even if Lilybeth had stabbed appellant once, the continuation and multiplicity of wounds negate reasonable necessity.
- The unborn fetus’s death qualified as unintentional abortion under Article 257: violence unintentionally exerted on a pregnant woman re
Case Syllabus (G.R. No. 179035)
Facts of the Case
- On 26 November 2002, at about 6:30 a.m. in Sitio Sogod, Sto. Domingo, Nabua, Camarines Sur, appellant Jesus Paycana, Jr., a butcher by trade, returned home carrying his work tools (knife, bolo, sharpener).
- His wife, Lilybeth Balandra-Paycana, then seven months pregnant, was preparing their children for school.
- Without apparent provocation, appellant stabbed Lilybeth fourteen (14) times, causing her immediate death and the death of the unborn child.
- Angelina Paycana, appellant’s eldest daughter (age 15), witnessed the assault through a window and saw her father strangling and repeatedly stabbing her mother.
- Tito Balandra, the victim’s father, heard his daughter’s cries, arrived at the scene, saw the victim prostrate and trembling, and observed the armed appellant withdraw.
- Dr. Stephen Beltran performed the autopsy on Lilybeth; Santiago Magistrado, Jr. embalmed the body and removed the deceased fetus.
Procedural History
- Appellant was arraigned before the Regional Trial Court (RTC) of Iriga City, Branch 37, and pleaded not guilty to complex parricide with unintentional abortion.
- During pre-trial, appellant admitted his marriage to Lilybeth but asserted self-defense as justification.
- On 14 April 2005, the RTC convicted him of the complex crime and imposed the penalty of death, plus civil indemnity (₱50,000), moral damages (₱50,000), and exemplary damages (₱25,000).
- Pursuant to Rule 122, Section 3(d) of the Rules of Criminal Procedure, the case was automatically elevated to the Court of Appeals (CA).
- On 30 May 2007, the CA affirmed the conviction but modified the penalty from death to reclusion perpetua under Republic Act No. 9346.
- Appellant filed a notice of appeal to the Supreme Court on 14 June 2007.
Issue
- Whether appellant successfully proved the justifying circumstance of self-defense to exculpate himself from criminal liability.
Appellant’s Claim of Self-Defense
- Alleged that his wife attacked him firs