G.R. No. L-1293; May 24, 1948
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MACARIO MANZANARES, accused-appellant.

FACTS

On September 15, 1943, in Barrio Canlalay, Bantayan, Cebu, Perfecto Manzanares was fatally stabbed in the abdomen and died within an hour. The accused, Macario Manzanares, is the son of the deceased. Due to the disruption of civil government during the enemy occupation, criminal prosecution was delayed until a complaint for parricide was filed in August 1946. The trial court convicted Macario and sentenced him to reclusion perpetua. He appealed, contesting the factual finding that he delivered the fatal blow. The prosecution presented witnesses (including the victim’s other son, Pio, and two grandchildren) who testified that Macario, after a beckoning, stabbed Perfecto without provocation and later also stabbed Pio when he intervened. The defense presented witnesses, including Macario, who claimed that Pio was the initial aggressor in a fight over land and chicken damage, and that Perfecto was accidentally stabbed when he tried to intervene between his two sons.

ISSUE

Who delivered the fatal stab wound that killed Perfecto Manzanares?

RULING

The Supreme Court affirmed the conviction. After carefully analyzing the testimonies, the Court found the prosecution witnesses more credible and consistent. The defense version was riddled with improbabilities and contradictions—such as why Pio, allegedly the aggressor intent on a death combat, would attack with a mere piece of bamboo while Macario was armed with a bolo, and why the father would only intervene after Pio had already switched weapons. The delay in filing the complaint, due to the post-war disruption of government, did not impair the prosecution witnesses’ credibility. Therefore, Macario Manzanares is guilty of parricide under the Revised Penal Code, without any modifying circumstance.

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