G.R. No. 214883 - People vs. Samson

Case Summary (G.R. No. 214883)

Factual Background

Cristina Samson was charged with parricide after stabbing her husband, Gerry Delmar, to death on June 27, 2002. Their marriage was marked by frequent quarrels. On the date in question, the victim, reportedly intoxicated, asked about dinner; upon learning no food was prepared, an altercation ensued. According to Cristina, Gerry, armed with a knife, threatened her life. She claimed to have disarmed him by pushing him and subsequently stabbing him when he grabbed her despite her warning. Her children and relatives offered conflicting accounts, with her daughter stating Cristina retrieved the knife from the roof and stabbed her father without immediate provocation.

Trial Court and Court of Appeals Findings

The Regional Trial Court (RTC) found Cristina guilty, rejecting her claim of self-defense as the threat had ceased once the husband was disarmed. The RTC emphasized that Cristina provoked Gerry by pushing him, and the stabbing lacked justification because the aggression was no longer present. The RTC sentenced her to reclusion perpetua and ordered indemnification for the heirs of the victim. The Court of Appeals (CA) affirmed the RTC ruling, noting Cristina’s flight and evasion of arrest for four years as evidence undermining her innocence, and agreeing that unlawful aggression had ceased before the fatal stabbing.

Issue on Appeal

The pivotal issue is whether the CA erred in not recognizing Cristina Samson’s plea of self-defense as a justifying circumstance negating her criminal liability for parricide.

Legal Framework on Self-Defense

Under Article 11, Section 2 of the RPC, self-defense is a justifying circumstance that admits the commission of the act but exempts the accused from criminal liability if proven by clear and convincing evidence. The requisites are: (1) unlawful aggression by the victim, (2) reasonable necessity of the means employed to prevent or repel the aggression, and (3) absence of sufficient provocation by the accused.

Analysis on Unlawful Aggression

The Supreme Court disagreed with the findings of the RTC and CA regarding the cessation of unlawful aggression. It ruled that unlawful aggression persisted when the accused stabbed her husband despite his disarmament because he continued advancing and grabbed her arm with intent, placing her life in actual and imminent danger. The Court drew parallels with the decision in People v. Rabandaban, which upheld self-defense even after the aggressor was partially disarmed but still posed an imminent threat. The aggressor’s refusal to retreat or cease aggression while the accused was armed justified the latter’s defensive action.

Reasonable Necessity of the Means Employed

The Court found that using the knife was a proportionate and reasonable means to avert the danger given the circumstances: the victim was stronger, had earlier threatened lethal harm, and physically grabbed the accused despite her warnings. The single stab wound to the chest indicated an instinctive defense against a real threat rather than excessive retaliation. The Court emphasized that strict equality of weaponry is not required so long as the means employed correspond reasonably to the imminent danger faced.

Lack of Sufficient Provocation on the Part of the Accused

The Court rejected the trial court’s finding that Cristina provoked the fatal incident. The act of pushing the husband after he pointed the knife away was deemed a passive defensive maneuver, not sufficient provocation that would negate self-defense. The accused capitalized on an opportunity to disarm herself in response to ongoing unlawful aggression.

Effect of Flight on Credibility

The Court recognized that Cristina’s four-year flight from arrest was weighed by the CA against her, suggesting consciousness of guilt. However, the appellant explained her flight was motivated by fear of retaliation from the victim’s relatives rather than an intention to evade ju

Case Syllabus (G.R. No. 214883)

Facts and Background

Cristina Samson was charged on August 14, 2002, with parricide under Article 246 of the Revised Penal Code for stabbing her husband, Gerry Delmar, on June 27, 2002, in Tarlac City, Philippines, resulting in his death.
The criminal information detailed that Cristina, armed with a knife, stabbed her husband on his chest with intent to kill.
Cristina entered a plea of not guilty during arraignment nearly four years later.
Trial proceeded with a reverse procedure since Cristina invoked the justifying circumstance of self-defense.

Version of the Defense

Cristina recounted that on the night of the incident, her husband Gerry, intoxicated, arrived home and, upon finding no food prepared, began insulting and physically assaulting her by slapping her.
An altercation ensued lasting about ten minutes, temporarily pacified by Cristina’s father’s arrival.
Gerry returned after thirty minutes, threatening Cristina with a knife at her neck, warning her to stop talking or face being stabbed.
After dual face slaps, Cristina pushed Gerry, causing him to fall.
She then took the knife from Gerry, held it in front of her chest as a warning, but Gerry grabbed her, at which time the knife penetrated his chest.
Upon seeing blood, Cristina called for help; her father and brother brought Gerry to the hospital, where he later died.
Her brother Allan confirmed hearing the fight, ignored initial disturbances, then responded to Cristina's cry for help, assisted in taking Gerry to the hospital, and notified other relatives.

Version of the Prosecution

Married since 1994, Cristina and Gerry had two daughters and lived near Cristina’s family.
Their union was marked by constant quarrels witnessed by children and relatives.
On June 27, 2002, Gerry, intoxicated, returned home and quarreled with Cristina over dinner being unavailable.
The youngest daughter, Christine, witnessed escalating violence culminating in Cristina obtaining a knife from the roof and stabbing Gerry.
Gerry crawled to the door and was rushed to the hospital but declared dead.
Cristina fled the scene, going to her father and subsequently evading arrest for four years.

Ruling of the Regional Trial Court (RTC)

The RTC rejected Cristina’s claim of self-defense, finding no ongoing threat to her life at the time of stabbing, as Gerry had already put down the knife.
The court noted Cristina’s act of pushing Gerry was provocative.
It concluded there was no unlawful aggression necessitating lethal defense once Gerry was disarmed.
Cristina was found guilty of parricide and sentenced to reclusion perpetua, alongside civil indemnity, moral damages, exemplary damages, and costs.

Ruling of the Court of Appeals (CA)

The CA affirmed the RTC decision, agreeing that the initial unlawful aggression ceased when Gerry disarmed.
It highlighted Cristina’s four-year evasion of arrest as contradictory to her innocence claim.
The CA