Case Summary (G.R. No. 80728)
Procedural History and Applicable Law
On August 19, 2005, the City Prosecutor of Tacloban filed an Information charging William with parricide for stabbing and killing his wife on August 17, 2005. William pleaded not guilty upon arraignment on March 21, 2006. The case was tried before the Regional Trial Court (RTC) of Tacloban City, which convicted him on February 24, 2016 of parricide, sentencing him to reclusion perpetua and ordering him to pay damages. The Court of Appeals (CA), in its decision dated May 31, 2017, affirmed the conviction with modifications on damages, and denied reconsideration on January 29, 2018. William appealed to the Supreme Court.
Facts Established During Trial
The victim and accused were married with five children and lived together in Tacloban City. On the night of August 17, 2005, their two daughters, Angela and Jessica, overheard loud arguing between their parents. The father punched the mother, who was holding the daughters, and then went to the kitchen, retrieved a knife, and stabbed her in the chest below the armpit. The mother attempted to leave the house but collapsed and died soon afterward. William admitted stabbing Delia but claimed the stabbing was accidental during a confrontation with another man allegedly caught in the act with his wife.
Issue Presented
The Court had to determine whether the CA correctly upheld William’s conviction for parricide, specifically examining the validity of William’s defense that the stabbing was accidental and whether mitigating circumstances applied.
Elements of Parricide and Proof
Parricide requires proof that (1) a person was killed, (2) the accused caused the death, and (3) the deceased was the accused’s legitimate spouse, parent, child, ascendant, or descendant. The victim’s death was established by her Death Certificate citing fatal stab wounds to the chest. The accused admitted to stabbing her, and the daughters provided eyewitness accounts consistent with this fact.
Credibility of Witnesses and Relationship of Parties
The daughters’ testimonies were found credible and showed no presence of any other person in the house during the incident. Their accounts contradicted William’s claim that he found his wife with another man. The mutual spousal relationship was uncontroverted, evidenced by the admission of the accused and the marriage certificate presented by the prosecution.
Defense Under Article 247 of the Revised Penal Code
William invoked Article 247, which mitigates penalty to “destierro” if a legally married person kills the spouse or the paramour upon surprising them in the act of sexual intercourse or immediately thereafter, provided there was no prior facilitation or consent to infidelity. The Supreme Court found William failed to prove this defense by clear and convincing evidence. The credible testimonies negated the presence of a paramour or infidelity at the time.
Assessment of Mitigating Circumstances
William argued passion and obfuscation, lack of intent to commit so grave a wrong, and voluntary surrender as mitigating circumstances. The Court rejected passion and obfuscation because the quarrel preceding the stabbing did not rise to the level of uncontrollable passion that would justify such mitigation.
Voluntary surrender was denied because there was no proof of spontaneity or unconditional intent to submit to authorities; mere compliance during police questioning does not amount to voluntary surrend
Case Syllabus (G.R. No. 80728)
Case Background and Procedural History
- The case involves accused-appellant William Sabalberino, charged with the crime of parricide for stabbing and killing his wife, Delia Fernandez-Sabalberino.
- On August 19, 2005, the City Prosecutor of Tacloban filed an Information charging William Sabalberino with parricide before the Regional Trial Court (RTC) of Tacloban City, Branch 6.
- Accused-appellant pleaded not guilty at the arraignment on March 21, 2006.
- Trial ensued, and on February 24, 2016, the RTC found William Sabalberino guilty of parricide, sentencing him to reclusion perpetua and ordering the payment of damages to the victim's heirs.
- The accused appealed to the Court of Appeals (CA), which, on May 31, 2017, affirmed the conviction but modified the damage awards, increasing amounts for moral, temperate, and exemplary damages, and imposed interest on all damage awards.
- The CA denied the accused-appellant’s Motion for Reconsideration on January 29, 2018.
- The accused-appellant filed a Notice of Appeal with the Supreme Court on March 16, 2018, which was given due course.
- The Office of the Solicitor General (OSG) and the accused-appellant both manifested adoption of their respective previously filed briefs instead of filing supplemental briefs.
Facts of the Case
- William Sabalberino and Delia Fernandez-Sabalberino were married and lived together with their five children in Tacloban City.
- On the early morning of August 17, 2005, their daughters Angela and Jessica heard and witnessed their parents arguing and saw William punch Delia in the face.
- William proceeded to the kitchen, retrieved a knife, and stabbed Delia in the chest below the armpit while she was holding their daughters.
- Delia attempted to walk to the door but collapsed and died shortly thereafter.
- William admitted to stabbing Delia but claimed the act was accidental, alleging he found Delia with a naked man and intended to stab the man, but Delia was in between.
- The daughters testified they saw no other man and that their parents were arguing prior to the stabbing.
- Delia’s Certificate of Death confirmed the cause of death as shock and hemorrhage due to a stab wound in the chest hitting the heart.
Issues Presented
- Whether the CA correctly upheld the conviction of William Sabalberino for the crime of parricide.
- Whether accused-appellant’s defense under Article 247 of the Revised Penal Code (RPC) for killing upon surprising a spouse in the act of sexual intercourse applies.
- Whether mitigating circumstances, including passion or obfuscation, voluntary surrender, and lack of intention to commit so grave a wrong, were properly considered.
Ruling on the Elements of Parricide
- Parricide is defined under Article 246 of the RPC as the killing of a person’s father, m