G.R. No. L-46999 and 47000. April 18, 1941.
EL PUEBLO DE FILIPINAS, plaintiff-appellee, vs. PRISCILA LAUREANO, ET AL., defendants-appellants.

FACTS

Two closely related cases were jointly tried in the Court of First Instance of Romblon. Case No. 2262 was against Priscila Laureano for parricide, and Case No. 2263 was against Serafin Alam, Romano Laureano, and Basilia Tugnao for murder. The incidents occurred on January 9, 1937, in Barrio Lanas, Island of Carabao, Municipality of Looc, Province of Romblon. The defendants were convicted: Priscila Laureano was sentenced to reclusion perpetua and to indemnify the heirs of the deceased Mauro Ortega P1,500. Serafin Alam, Romano Laureano, and Basilia Tugnao were each sentenced to an indeterminate penalty of 2 years, 4 months, and 1 day of prision mayor to 8 years and 1 day of prision mayor, and to pay jointly and severally an indemnity of P500 to the heirs. The defendants appealed.
The prosecution’s case, based on the testimonies of Maura Gregorio, Vicente Tugnao, and Sulpicio Tugnao, established the following facts: On the night of January 9, 1937, a dispute arose between Priscila Laureano and her husband, Mauro Ortega, after he beat her with a stick. Priscila fled to her parents’ house. Her mother, Basilia Tugnao, went to the couple’s house and argued with Mauro. Priscila then returned accompanied by her father, Romano Laureano, and Serafin Alam (the barrio lieutenant). Mauro fled out a window and ran towards Graciano Domingo’s house but tripped and fell, whereupon he was caught by his pursuers. Alam struck him on the nape with a stick, and Romano Laureano hit him on the right leg with a piece of cane. Mauro, unconscious, was carried back to his house. There, while Alam, Romano Laureano, and Dominga Perez (Alam’s wife) held Mauro in a reclining position, Priscila took a pointed bolo and stabbed him in the abdomen. Maura Gregorio and Vicente Tugnao witnessed this from the balcony. The next day, Alam told Pablo Colindres (the victim’s half-brother) that Mauro had committed suicide. Pablo observed a wound in the abdomen, a contusion on the nape, and a wound below the right knee. The body was in an advanced state of putrefaction when examined by Dr. Medalla, who initially reported it appeared to be a case of suicide but later testified his report was based on information he had received about suicide.

ISSUE

The sole issue raised by the defense is one of fact: whether the trial court erred in accepting the testimonies of the prosecution witnesses and rejecting the defense theory of suicide, thereby erroneously convicting the defendants.

RULING

The Supreme Court affirmed the convictions but modified the appreciation of circumstances.
1. The trial court did not err in crediting the testimonies of the prosecution witnesses (Maura Gregorio, Vicente Tugnao, and Sulpicio Tugnao). Their testimonies were consistent and credible. The defense’s attacks on their credibility were unfounded. Maura Gregorio’s explanation for going to a farther house to ask for matches was reasonable. Vicente Tugnao’s initial failure to disclose the truth during the early investigation was satisfactorily explained as having been done under the instruction of the accused Serafin Alam, who was the barrio lieutenant. The alleged motives for Vicente’s testimony were not substantiated.
2. The trial court correctly rejected the defense theory of suicide. The evidence established that the fatal abdominal wound was inflicted by Priscila Laureano while the victim was unconscious and being held by the other accused.
3. Regarding the liability of the accused:
For Priscila Laureano (parricide), the Supreme Court affirmed the penalty of reclusion perpetua but modified the appreciation of circumstances. The aggravating circumstance of alevosia* (treachery) was present because the victim was unconscious when stabbed. However, the mitigating circumstance of provocation on the part of the victim was also applicable, as Priscila had just been severely beaten by her husband and there was no sufficient break between his act and hers. Applying these offsetting circumstances to the indivisible penalty of reclusion perpetua to death, the lesser penalty of reclusion perpetua was properly imposed.
* For Serafin Alam, Romano Laureano, and Basilia Tugnao (murder), the Supreme Court found no evidence that they had knowledge of Priscila’s criminal purpose to kill Mauro or that they rendered efficient aid in the commission of the parricide. Their liability was only for the physical injuries they inflicted (Alam striking the nape, Romano striking the leg). Their conviction for the complex crime of murder was improper. The Court accepted the Solicitor General’s recommendation and modified their liability accordingly. Considering their period of detention since May 29, 1939, and their entitlement to credit for half of that time, the Court ordered their immediate release.
DISPOSITIVE:
The appealed judgment was affirmed with modification: Priscila Laureano’s sentence was affirmed. The conviction of Serafin Alam, Romano Laureano, and Basilia Tugnao for murder was set aside, and they were ordered immediately released. Costs were assessed against appellant Priscila Laureano.