Case Summary (G.R. No. 14170)
Factual Background
The events unfolded during a supper gathering which included Merced, Apolonia, and the owner of the house, Teodora Sarasin. After supper, both Merced and Apolonia retired to the main room of the house to sleep. Sarasin later awoke to sounds of a struggle and heard Apolonia indicate that she was wounded. Upon returning to the room, she discovered Pantaleon Arabe lying on the floor, bloodied, with a mortal wound inflicted on his side. This was later confirmed by a health officer who concluded that the fatal wound had been made by a double-edged dagger.
Testimonies and Evidence
Multiple testimonies were presented, including that of Teodora Sarasin, who indicated the dynamics during the struggle and her discovery of Arabe's body. Additionally, Filomena Ago, the sister-in-law of Merced, testified that prior to the incident, Apolonia had expressed grievances regarding her husband’s suspicions of her relationship with Merced. This included a specific incident where Apolonia brandished a dagger in a moment of anger. The investigation found the same dagger, bathed in blood, which was allegedly linked to the events of that night.
Defense Claims
Both defendants pleaded not guilty, with Merced claiming he acted in self-defense. He contended that Arabe attacked him with a bolo and claimed that he wounded Arabe only after successfully disarming him. Patron did not provide any defense at trial. The court scrutinized the credibility of Merced’s plea for self-defense, noting the nature of Arabe's actions as a husband protecting his honor against perceived infidelity.
Legal Analysis
The court found that the evidence established the elements of homicide under Article 404 of the Penal Code, as the death of Pantaleon Arabe resulted from a single serious wound without qualifying circumstances that could elevate the act to murder as defined in Article 503. Testimonies indicated no disinterested witness to the struggle, and the narrative of events was primarily drawn from the accounts of the parties involved.
Affirmation of Judgment
Ultimately, the court affirmed the guilty verdict against Catalino Merced, sentencing him to fourteen years, eight months, and one day of reclusion temporal, along with a civil in
...continue readingCase Syllabus (G.R. No. 14170)
Case Background
- This case involves the defendants Catalino Merced and Apolonia Patron who were charged with homicide by the provincial fiscal before the Court of First Instance of Oriental Negros.
- The trial concluded with a judgment on April 29, 1918, sentencing Catalino Merced to fourteen years, eight months, and one day of reclusion temporal, along with accessory penalties, and to pay indemnity of P1,000 to the heirs of the deceased, Pantaleon Arabe.
- Apolonia Patron received a sentence of eight years and one day of prision mayor, with similar penalties and indemnity responsibilities.
- The defendants appealed the judgment.
Incident Details
- The incident occurred on the night of March 4, 1918, at the house of Teodora Sarasin in the barrio of Palimpinon, Luzuriaga.
- Catalino Merced and Apolonia Patron were invited to supper by Sarasin and later retired to the main room to rest.
- Teodora Sarasin was awakened by the sound of a struggle in the room where the defendants were resting.
- Sarasin overheard Apolonia claim to her husband, Pantaleon Arabe, that she was wounded, and Arabe responded, “That is what you got.”
Discovery of the Victim
- After hearing the commotion, Sarasin left the house for fear and later returned to find Pantaleon Arabe lying bloody on the mat.
- Following