G.R. No. 91115 December 29, 1992
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PACALSO MAT-AN Y KUTBING/KATUBING, accused-appellant.
FACTS
On December 24, 1986, accused-appellant Pacalso Mat-an, while drunk and holding a pine tree branch, went to his sister Brenda’s house to confront her about a spilled water issue. Despite her agreement to pay half his water bill, he struck her with the branch. His brother David Mat-an, who had followed him knowing his violent tendencies when drunk, witnessed this and tried to pacify him. An argument then ensued between the accused-appellant and their mother, Martha Mat-an, about a money debt. During this argument, the accused-appellant struck his mother on the head with a piece of wood. To prevent further harm, David hit the accused-appellant’s chest with an axe, causing the latter to flee. The mother was brought to the hospital but was pronounced dead on arrival. An autopsy revealed her cause of death as neurogenic shock secondary to contrecoup injuries of the brain, subdural hemorrhage, and basal skull fracture due to application of physical violence on the head. The accused-appellant was arrested the next day. At trial, the accused-appellant claimed he only slapped his sister after she cursed him, and that he swung a piece of wood at David in self-defense after David attacked him with an axe, accidentally hitting his mother instead. The Regional Trial Court found him guilty of parricide.
ISSUE
Whether the trial court erred in finding the accused-appellant guilty of parricide beyond reasonable doubt, rejecting his defenses of accident and lack of criminal intent.
RULING
The Supreme Court affirmed the trial court’s decision with modification. The Court upheld the trial court’s assessment of the credibility of the prosecution witnesses, whose testimonies were direct, simple, and consistent, and who had no improper motive to testify falsely. The Court found the accused-appellant’s version less credible, noting he was ready for trouble, was violent (having previously killed his own brother), and his claimed self-defense was improbable given the nature of the axe wound he received, which would have immobilized him. The Court ruled that the exempting circumstance of accident under Article 12 of the Revised Penal Code did not apply because the accused-appellant was not performing a lawful act with due care when the incident occurred; his act of hitting was unlawful. The Court modified the civil indemnity, increasing it to P50,000.00 in accordance with prevailing jurisprudence.