Case Summary (G.R. No. 46530)
Facts of the Case
The events leading to the conviction indicate that Catalino Rabao and Salvacion Agawa were happily married since January 15, 1936, and had a child. On the morning of the incident, following a late night due to local elections, Rabao argued with his wife regarding bathing their sick child, which escalated into physical violence when he punched her in the abdomen. Agawa fell and subsequently died from a ruptured spleen attributed to the blow delivered by her husband. An autopsy performed by Dr. Vicente Roxas confirmed the cause of death as internal hemorrhage due to the spleen's rupture.
Legal Proceedings
Following the incident, Rabao was charged with parricide. The prosecution presented eyewitness testimony, notably from Urbano Rellora, who witnessed the assault, as well as the corroborative findings from the autopsy. The defense argued that Rabao’s actions amounted to reckless imprudence rather than parricide, challenging the assertion that his blow directly resulted in the fatal injury.
Court's Analysis
The court determined that there was no error in the lower court's finding that Rabao's actions were intentional and led to his wife's death. Contrary to the defense's claims, the evidence firmly supported the conclusion that Rabao’s blow was not an act of reckless imprudence but a deliberate violent act that violated the provisions of the Revised Penal Code. The lower court's ruling was reinforced by the credibility of the witnesses, particularly the testimony of Rellora and the autopsy results.
Sentencing and Mitigating Factors
While parricide under Article 246 of the Revised Penal Code typically carries the penalty of reclusion perpetua to death, the court recognized mitigating circumstances in Rabao's case such as the lack of intent to commit such a grave crime, an impulsive reaction due to passion, and his voluntary surrender to authorities after the commission of the crime. Consequently, the appellate decision modified the original sentencing to impose the lesser penalty of reclusion p
...continue readingCase Syllabus (G.R. No. 46530)
Case Overview
- Court: Court of First Instance of Camarines Sur
- Case Number: G.R. No. 46530
- Date of Decision: April 10, 1939
- Parties Involved:
- Plaintiff and Appellee: The People of the Philippines
- Defendant and Appellant: Catalino Rabao
- Judgment: Conviction for parricide, sentenced to an indeterminate penalty of 8 years and 1 day of prision mayor to 20 years of reclusion temporal, ordered to indemnify the heirs of the deceased, and to pay costs.
Facts of the Case
- Marriage: Catalino Rabao and Salvacion Agawa were married on January 15, 1936, and had a child of tender age.
- Living Situation: The couple resided in the home of Urbano Rellora, who lived with the mother of the accused.
- Incident: On December 15, 1937, after having stayed up late due to local elections, Catalino noticed his wife preparing water for their child’s bath, which he objected to due to the child's cold.
- Quarrel: A dispute ensued, during which Catalino struck Salvacion in the abdomen, leading to her collapse and subsequent death.
Medical Examination
- Autopsy: Conducted by Dr. Vicente Roxas the following day.
- Findings:
- The deceased had an enlarged spleen due to malaria.
- Death was determined to be caused by hemorrhage from a ruptured spleen, which was attributed to the blow delivered by the accused.
Testimonies
- Urbano Rellora: Testified that he witnessed Catalino punch his wife in the abdomen, after which she fell and suffered an attack leading to her d