Case Summary (G.R. No. L-36858)
Factual Background
On May 21, 1970, Asuncion Pablo Ulep died in San Nicolas, Ilocos Norte. She was the legally married wife of Macario A. Ulep. The Chief of Police initially received a report that the deceased had died of a heart attack. The husband at first refused permission for an autopsy. A daughter of the deceased later asked for time and shortly before burial requested that an autopsy be performed, after which the police and Dr. Eliseo Bonoan intercepted the funeral procession at the Catholic cemetery and conducted a post-mortem examination.
Autopsy Findings
Dr. Eliseo V. Bonoan conducted the necropsy and prepared a written post-mortem report dated May 25, 1970. The report recorded blunt-force injuries including a rectangular bluish-black area on the left upper arm and multiple complete rib fractures: left 4th, 5th, 6th, and 7th ribs and right 3rd and 4th ribs, with extravasated blood and tissue injury surrounding the fractures. The thoracic cavity contained about 200 cc of serous fluid with pleural lacerations at fracture points. The abdominal cavity contained about 500 cc of serous fluid. The central nervous system showed congested meningeal vessels. The pathological diagnosis listed the cause of death as "CARDIAC ARREST PRIMARY SHOCK."
Admissions and Subsequent Retraction
Two weeks after burial, two constabulary sergeants investigated Macario A. Ulep. He executed a written statement, marked Exhibit "A", and sworn before Fiscal Cesar Abaya, admitting he had elbowed his wife and caused her death. A subsequent written statement by the accused, marked Exhibit "B", repeated that he elbowed his wife on the breast at about 5:30 p.m., that she vomited and went to bed, and that he returned later to find her dead. At trial the accused recanted those affidavits and testified that he had not inflicted the fatal injuries but relied on an earlier accident more than a year before when a bullcart allegedly pinned the wife and fractured ribs, and that she had been treated by an arbularyo.
Trial Court Proceedings and Sentence
The Court of First Instance of Ilocos Norte convicted Macario A. Ulep of parricide for the killing of his wife. The trial court sentenced him to reclusion perpetua and ordered indemnity of P12,000.00 plus costs, in a decision rendered March 20, 1973. The trial judge noted that the accused never attempted to repudiate his sworn statements admitting the elbow blows that caused the death.
Issues Raised on Appeal
The accused urged three principal errors: (1) that his admissions in Exhibits "A" and "B" were mere belief and not proof of causation; (2) that the cause of death was a long-standing disease or chronic condition, as testified by Dr. Pedro Blanco for the defense; and (3) that the trial court therefore erred in not acquitting him of parricide.
Parties' Contentions
The People of the Philippines relied on the necropsy findings and the accused's sworn admissions to prove that elbow blows inflicted by Macario A. Ulep produced the fractured ribs and caused cardiac arrest and primary shock. The defense contended that the rib fractures were of long standing, that absence of external contusion showed the elbow blows lacked force to fracture ribs, that the fractures were not depressed so as to injure the heart, and that serous fluid and clots indicated chronic disease such as nephritis, hepatic hardening, or cardiac weakening rather than traumatic causation. The defense medical witness, Dr. Pedro Blanco, testified that he had not attended a case of fractured ribs and advanced the possibility of chronic internal disease as causal.
Supreme Court's Findings on Causation
The Court accepted the necropsy report of Dr. Bonoan and found no fault in its conclusion that death resulted from cardiac arrest and primary shock caused by the blunt-force injuries to the chest. The Court observed that the accused had admitted in sworn affidavits (Exhibits "A" and "B") that he elbowed his wife many times on the breast and that the trial court correctly observed that the accused never repudiated those statements. The Court found the evidence sufficient to establish that the elbow blows produced the rib fractures and that those injuries were the efficient and proximate cause of death or at least accelerated the death.
Legal Reasoning and Authorities
The Court explained that death may result from shock attendant upon an injury even when external signs are minimal, citing medical authority Wharton & Stille's Medical Jurisprudence on shock and reported decisions illustrating fatal shock f
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Case Syllabus (G.R. No. L-36858)
Parties and Procedural Posture
- PEOPLE OF THE PHILIPPINES prosecuted the case for the death of the victim before the Court of First Instance of Ilocos Norte, Second Judicial District.
- MACARIO A. ULEp was the accused at trial and appellant on appeal to the First Division.
- The trial court convicted the accused of parricide and sentenced him to reclusion perpetua with an indemnity award of P12,000 and costs in a decision dated March 20, 1973.
- The First Division reviewed the appeal and affirmed the conviction with modification of the indemnity amount on June 20, 1988.
Key Facts
- The victim, Asuncion Pablo Ulep, died on May 21, 1970 at about nine o'clock in the evening in San Nicolas, Ilocos Norte.
- The husband, MACARIO A. ULEP, was present at the house and reported the death to the barrio captain and to local authorities.
- The husband initially refused permission for an autopsy but later allowed it when the deceased's daughter requested time to decide.
- The autopsy was performed at the cemetery shortly before burial by Dr. Eliseo V. Bonoan and the police who caught up with the funeral procession.
Autopsy Findings
- Dr. Eliseo V. Bonoan recorded complete fractures of the 4th, 5th, 6th and 7th ribs on the left and fractures of the 3rd and 4th ribs on the right with extravasated blood and injuries to surrounding tissues.
- The thoracic cavity contained about 200 cc. of serous fluid and pleural lacerations were present at the points of fracture.
- The abdominal cavity contained about 500 cc. of serous fluid and the heart and large vessels contained a small amount of clotted blood with congested coronary vessels.
- The meningeal vessels were congested and the stated cause of death in the necropsy report was "CARDIAC ARREST PRIMARY SHOCK."
Confessions and Retraction
- Two written statements, marked Exhibit "A" and Exhibit "B", were prepared and sworn to before Fiscal Cesar Abaya in which the accused admitted elbowing his wife and causing her death.
- In court, the accused retracted the prior admissions and testified that the deceased had sustained rib fractures more than a year earlier when a bullcart accident pinned her chest and she was treated by a local "arbularyo."
Medical Contentions
- The prosecution medical witness, Dr. Bonoan, testified that the rib fractures and associated injuri