G.R. No. 102351 March 22, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIO LIBUNGAN y SABADO, accused-appellant.

FACTS

On or about midnight of September 26, 1987, accused-appellant Mario Libungan returned to his house from work and quarreled with his wife, Juanita dela Cruz Libungan, about money. Juanita went to the kitchen. Mario put a white shirt over his head, covering it except for his eyes and nose. When Juanita returned, Mario tackled (“pinatid”) her, causing her to fall. When she tried to get up, he kneeled over her (“tinuhuran”) and stabbed her twice with a pointed, sharp-bladed weapon (like a balisong or “kutsilyo”): once on the left side of the back (a fatal wound hitting the kidney) and once on the upper chest. She also sustained seven other contusions and abrasions. After stabbing her, Mario left through the kitchen, destroying a portion of the wall to make it appear someone else had entered. The victim’s brothers, Alberto, Josefino, and Eduardo dela Cruz, were awakened by the cries of children from their sister’s house. They found Juanita near the house of Maring (the accused’s sister), being helped by Arsing. Juanita told her brothers she was stabbed by Mario. They brought her to the hospital, but she died en route. The police and the brothers went to the Concrete Aggregates Crushing Plant, where Mario worked, and invited him for questioning around 2:30 a.m. The prosecution’s case relied heavily on the testimony of the couple’s seven-year-old son, Crisanto Libungan, who witnessed the killing. A marriage contract proved the legal marriage between the accused and the victim. The accused invoked the defense of alibi, claiming he was at work when the crime occurred and that a thief killed his wife.

ISSUE

Whether the accused-appellant, Mario Libungan, is guilty beyond reasonable doubt of the crime of parricide for killing his wife, Juanita dela Cruz Libungan.

RULING

The Supreme Court AFFIRMED the decision of the Regional Trial Court convicting the accused-appellant of parricide, with the modification that the amount of damages be increased from P30,000.00 to P50,000.00. The Court found the testimony of the seven-year-old eyewitness, Crisanto Libungan, clear, convincing, and credible despite minor inconsistencies, which were deemed natural and even strengthened his credibility. The witness positively identified his father as the perpetrator. His testimony was corroborated by the victim’s dying declaration to her brothers and their subsequent actions. The accused’s defense of alibi failed because he was positively identified and the distance between his workplace and the crime scene (three kilometers, traversable in 10-15 minutes) did not make it physically impossible for him to have committed the crime. The Court also held that the relationship of the victim’s brothers to her did not discredit their testimony.