G.R. No. 30125 , January 21, 1929
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. JUAN ALANGUILANG, defendant-appellant.

FACTS

The accused, Juan Alanguilang, was charged with the crime of parricide for killing his lawful wife, Aurelia Brion. The Court of First Instance of Laguna found him guilty and sentenced him to life imprisonment, with accessories, an indemnity of P500 to the heirs of the deceased, and costs. The accused appealed, arguing that: (1) the trial court abused its discretion in denying his motions for postponement; (2) his conviction was based on contradictory or incredible testimony; and (3) even if responsible, he had no intent to kill, as his mind was obfuscated by jealousy at the time.

ISSUE

1. Did the trial court abuse its discretion in denying the motions for postponement?
2. Was the conviction based on sufficient and credible evidence?
3. Should the mitigating circumstance of obfuscation be considered in favor of the accused?

RULING

The Supreme Court AFFIRMED the judgment of the trial court in all respects.

1. On the denial of postponement: The Supreme Court found no abuse of discretion. The motions were not made by the attorney de oficio but by another absent attorney. When denied, the trial had not yet commenced, and the requesting attorney did not subsequently ask for time to prepare.

2. On the sufficiency of evidence: The Court found the evidence of guilt sufficient and credible. The testimonies of witnesses Clemente Alanguilang and Petronilo Balam, who partially witnessed the attack, were deemed worthy of credit and were corroborated by the contusions found on the victim’s body during autopsy. The Court gave more weight to the prior sworn statements and affidavits (Exhibits X, Y, Z) of the accused’s son, Buenaventura, and witness Victoria Magnaye, made before the chief of police and the justice of the peace, than to their subsequent exculpatory testimony during trial, which the Court disbelieved.

3. On the mitigating circumstance of obfuscation: The Court ruled that the requisites for obfuscation were not proven. For obfuscation to be considered, there must be proof of: (a) an act both unlawful and sufficient to produce such a state of mind, and (b) that the act was not far removed in time from the commission of the crime, allowing the perpetrator to recover his equanimity. These conditions were not established in the record.

*No pronouncement as to costs.*